SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 4, 2026

Martin Brenner
Chief Executive Officer
iBio, Inc.
11750 Sorrento Valley Road, Suite 200
San Diego, CA 92121

 Re: iBio, Inc.
 Registration Statement on Form S-3
 Filed February 27, 2026
 File No. 333-293864
Dear Martin Brenner:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Tyler Howes at 202-551-3370 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Melissa Palat Murawsky, Esq.
</TEXT>
</DOCUMENT>

CORRESP
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March 4, 2026

VIA EDGAR

United States Securities

and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Tyler Howes

    Re:
    iBio, Inc.

    Registration Statement on Form S-3

    Filed February 27, 2026

    File No: 333-293864

Dear Mr. Howes:

iBio, Inc. (the “Registrant”)
hereby requests that the effective date of the above-referenced Registration Statement on Form S-3 (File No. 333-293864), be accelerated
by the U.S. Securities and Exchange Commission (the “Commission”) to become effective on Friday, March 6, 2026,
at 5:00 p.m., Eastern Time, or as soon as reasonably practicable thereafter.

The Registrant understands
that the Staff of the Commission will consider this request as confirmation by the Registrant that it is aware of its responsibilities
under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement.

The Registrant hereby authorizes
Leslie Marlow or Melissa Palat Murawsky of Blank Rome LLP to orally modify or withdraw this request for acceleration. Please contact Leslie
Marlow at (212) 885-5358 or Melissa Palat Murawsky at (215) 569-5732 with any questions you may have concerning this request, and please
notify either of them when this request for acceleration has been granted.

    Very truly yours,

    IBIO, INC.

    By:
    /s/ Marc A. Banjak

    Name:
    Marc A. Banjak

    Title:
    Chief Legal Officer

cc:   Leslie Marlow, Blank Rome LLP

Melissa Palat Murawsky, Blank Rome LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 18, 2025

Martin Brenner
Chief Executive Officer
iBio, Inc.
11750 Sorrento Valley Road, Suite 200
San Diego, CA 92121

 Re: iBio, Inc.
 Registration Statement on Form S-3
 Filed June 13, 2025
 File No. 333-288000
Dear Martin Brenner:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Lauren Hamill at 303-844-1008 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Melissa Murawsky
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 June 18, 2025

 VIA EDGAR

 United States Securities

 and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Lauren Hamill

 Re:
 iBio, Inc.

 Registration Statement on Form S-3

 Filed June 13, 2025
 File No: 333-28800

 Dear Ms. Hamill:

 iBio, Inc. (the " Registrant ")
hereby requests that the effective date of the above-referenced Registration Statement on Form S-3 (File No. 333-28800), be accelerated
by the U.S. Securities and Exchange Commission (the " Commission ") to become effective on Monday, June 23, 2025 ,
at 5:00 p.m ., Eastern Time, or as soon as reasonably practicable thereafter.

 The Registrant understands
that the Staff of the Commission will consider this request as confirmation by the Registrant that it is aware of its responsibilities
under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement.

 The Registrant hereby authorizes
Leslie Marlow and/or Melissa Murawsky of Blank Rome LLP to orally modify or withdraw this request for acceleration. Please contact Ms.
Marlow at (212) 885-5358 or Ms. Murawsky n at (215) 569-5732 with any questions you may have concerning this request, and please notify
either of them when this request for acceleration has been granted.

 Thank you.

 Very truly yours,

 IBIO, INC.

 By:
 /s/ Marc Banjak

 Name:
 Marc Banjak

 Title:
 Chief Legal Officer

 cc: Leslie Marlow, Blank Rome LLP
 Melissa Murawsky, Blank Rome LLP

CORRESP
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February 7, 2025

VIA EDGAR

United States Securities

and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Jessica Dickerson

    Re:
    iBio, Inc.

    Registration Statement on Form S-3

    Filed January 31, 2025

    File No: 333-284647

Dear Ms. Dickerson:

iBio, Inc. (the “Registrant”)
hereby requests that the effective date of the above-referenced Registration Statement on Form S-3 (File No. 333-284647), be accelerated
by the U.S. Securities and Exchange Commission (the “Commission”) to become effective on Monday, February 10, 2025,
at 5:00 p.m., Eastern Time, or as soon as reasonably practicable thereafter.

The Registrant understands
that the Staff of the Commission will consider this request as confirmation by the Registrant that it is aware of its responsibilities
under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement.

The Registrant hereby authorizes
Leslie Marlow of Blank Rome LLP to orally modify or withdraw this request for acceleration. Please contact Leslie Marlow at (212) 885-5358
or Melissa Palat Murawsky at (215) 569-5732 with any questions you may have concerning this request, and please notify either of them
when this request for acceleration has been granted.

    Very truly yours,

    IBIO, INC.

    By:
    /s/ Marc A. Banjak

    Name:
    Marc A. Banjak

    Title:
    Chief Legal Officer

cc:   Leslie Marlow, Blank Rome LLP

Melissa Palat Murawsky, Blank Rome LLP

February 6, 2025
Martin Brenner
Chief Executive Officer
iBio, Inc.
11750 Sorrento Valley Road, Suite 200
San Diego, CA 92121
Re:iBio, Inc.
Registration Statement on Form S-3
Filed January 31, 2025
File No. 333-284647
Dear Martin Brenner:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Jessica Dickerson at 202-551-8013 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Leslie Marlow, Esq.

CORRESP
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  August 2, 2024

VIA EDGAR

United States Securities

and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Daniel Crawford

    Re:
    iBio, Inc.

    Registration Statement on Form S-3

    Filed July 3, 2024, as amended

    File No: 333-280680

Dear Mr. Crawford:

iBio, Inc. (the “Registrant”)
hereby requests that the effective date of the above-referenced Registration Statement on Form S-3 (File No. 333-280680), be accelerated
by the U.S. Securities and Exchange Commission (the “Commission”) to become effective on Tuesday, August 6, 2024,
at 4:00 p.m., Eastern Time, or as soon as reasonably practicable thereafter.

The Registrant understands
that the Staff of the Commission will consider this request as confirmation by the Registrant that it is aware of its responsibilities
under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement.

The Registrant hereby authorizes
Leslie Marlow of Blank Rome LLP to orally modify or withdraw this request for acceleration. Please contact Leslie Marlow at (212) 885-5358
or Melissa Palat Murawsky at (215) 569-5732 with any questions you may have concerning this request, and please notify either of them
when this request for acceleration has been granted.

    Very truly yours,

    IBIO, INC.

    By:
    /s/ Felipe Duran

    Name:
    Felipe Duran

    Title:
    Chief Financial Officer

  cc:
  Leslie Marlow, Blank Rome LLP

Melissa Palat Murawsky, Blank Rome LLP

CORRESP
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1271 Avenue of the Americas | New York, New York 10020

Blankrome.com

July 25, 2024

VIA EDGAR

United States Securities

and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:

 Re: iBio, Inc.

Registration Statement on Form S-3

Filed July 3, 2024

File No. 333-280680

Dear Mr. Crawford:

On behalf of our client, iBio,
Inc. (the “Company”), we submit this letter in response to comments from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) contained in its letter dated July 3, 2024 (the “Comment
Letter”), relating to the above-referenced Registration Statement on Form S-3 (the “Registration Statement”).
We are concurrently submitting via EDGAR an Amendment No. 1 to the Registration Statement (the “Amendment”).

Set forth below in bold
are comments from the Comment Letter. For your convenience, each of the numbered paragraphs below corresponds to the numbered comment
in the Staff’s Comment Letter and includes the caption used in the Comment Letter. Immediately following each comment is the Company’s
response to that comment.

Registration Statement on Form S-3
Prospectus Summary Overview, page 1

 1. Please revise your Prospectus Summary Overview to provide context
and balance to your discussion of your platform and AI-engine. For instance, please highlight, if true, that you have a limited operating
history developing vaccines and therapeutics, that you have not conducted clinical trials on any product candidates, and that there is
a risk that you may be unsuccessful in developing or commercializing any product candidates.

Response: In response to the Staff’s
comment, the Prospectus Summary Overview has been updated.

 2. Please revise to explain your basis for making all performance
and leadership claims, including the following ones:

 · Your belief that you “lead the field with (y)our patented AI-engine uncovering ‘hard to develop’ molecules;”

 · Your “groundbreaking EngageTx™ technology enables (you) to target bi-specific molecules;”

 · Your ability to “navigate sequence diversity and promote Human-Cyno cross reactivity while mitigating cytokine release;”

United States Securities

and Exchange Commission

July 25, 2024

Page 2

 · Your “unparalleled epitope engine stands out by allowing the ability to target select regions of a protein, potentially removing
the lengthy trial and error out of mAb discovery;”

 · Your AI-engine is expected to “increase the probability of success.”

Response: In response to the Staff’s comment, the
Company has revised the disclosure in the Amendment.

In accordance with your letter, we acknowledge
the Company is responsible for the accuracy and adequacy of the disclosures in its filings, notwithstanding any review, comments, action
or absence of action by the Staff.

Please contact me at (212)
885-5358 or Melissa Palat Murawsky at (215) 569-5732 with any questions or further comments regarding the response to the Staff’s
comments.

    Sincerely,

    /s/ Leslie Marlow

    Leslie Marlow

July 18, 2024
Martin Brenner
Chief Executive Officer and Chief Scientific Officer
iBio, Inc.
11750 Sorrento Valley Road, Suite 200
San Diego, CA 92121
Re:iBio, Inc.
Registration Statement on Form S-3
Filed July 3, 2024
File No. 333-280680
Dear Martin Brenner:
            We have conducted a limited review of your registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Registration Statement on Form S-3
Prospectus Summary
Overview, page 1
1.Please revise your Prospectus Summary Overview to provide context and balance to your
discussion of your platform and AI-engine. For instance, please highlight, if true, that you
have a limited operating history developing vaccines and therapeutics, that you have not
conducted clinical trials on any product candidates, and that there is a risk that you may
be unsuccessful in developing or commercializing any product candidates.
Please revise to explain your basis for making all performance and leadership claims,
including the following ones:
•Your belief that you “lead the field with (y)our patented AI-engine uncovering ‘hard
to develop’ molecules;”
•Your “groundbreaking EngageTx™ technology enables (you) to target bi-specific
molecules;”2.

July 18, 2024
Page 2
•Your ability to “navigate sequence diversity and promote Human-Cyno cross
reactivity while mitigating cytokine release;”
•Your “unparalleled epitope engine stands out by allowing the ability to target select
regions of a protein, potentially removing the lengthy trial and error out of mAb
discovery;”
•Your AI-engine is expected to “increase the probability of success.”
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Daniel Crawford at 202-551-7767 or Joe McCann at 202-551-6262 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Melissa Palat Murawsky, Esq.

CORRESP
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  April 22, 2024

VIA EDGAR

United States Securities

and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Jimmy McNamara

    Re:
    iBio, Inc.

    Registration Statement on Form S-3

    Filed April 16, 2024

    File No: 333-278729

Dear Mr. McNamara:

iBio, Inc. (the “Registrant”)
hereby requests that the effective date of the above-referenced Registration Statement on Form S-3 (File No. 333-278729) (the “Registration
Statement”), be accelerated by the U.S. Securities and Exchange Commission (the “Commission”) to become effective
on Wednesday, April 24, 2024, at 4:00 p.m., Eastern Time, or as soon as reasonably practicable thereafter.

The Registrant understands
that the Staff of the Commission will consider this request as confirmation by the Registrant that it is aware of its responsibilities
under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement.

The Registrant hereby authorizes
Leslie Marlow of Blank Rome LLP to orally modify or withdraw this request for acceleration. Please contact Ms. Marlow at (516) 457-4238
with any questions you may have concerning this request, and please notify Ms. Marlow when this request for acceleration has been granted.

    Very truly yours,

    IBIO, INC.

    By:
    /s/ Felipe Duran

    Name:
    Felipe Duran

    Title:
    Chief Financial Officer

cc:   Leslie Marlow, Blank Rome LLP

United States securities and exchange commission logo
April 22, 2024
Felipe Duran
Chief Financial Officer
iBio, Inc.
8800 HSC Parkway
Bryan, Texas 77807
Re:iBio, Inc.
Registration Statement on Form S-3
Filed April 16, 2024
File No. 333-278729
Dear Felipe Duran:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Jimmy McNamara at 202-551-7349 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Leslie Marlow

CORRESP
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November 30, 2023

VIA EDGAR

United States Securities

and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Tamika Sheppard

    Re:
    iBio, Inc.

    Registration Statement on Form S-1

    Filed October 27, 2023

    File No: 333-275204

Dear Ms. Sheppard:

iBio, Inc. (the “Registrant”)
hereby requests that the effective date of the above-referenced Registration Statement on Form S-1 (File No. 333-275204), be
accelerated by the U.S. Securities and Exchange Commission (the “Commission”) to become effective on Monday, December 4,
2023, at 5:00 p.m., Eastern Time, or as soon as reasonably practicable thereafter.

The Registrant understands
that the Staff of the Commission will consider this request as confirmation by the Registrant that it is aware of its responsibilities
under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement.

The Registrant hereby authorizes
Leslie Marlow of Blank Rome LLP to orally modify or withdraw this request for acceleration. Please contact Ms. Marlow at (516) 457-4238
with any questions you may have concerning this request, and please notify either of them when this request for acceleration has been
granted.

    Very truly yours,

    IBIO, INC.

    By:
    /s/ Felipe Duran

    Name:
    Felipe Duran

    Title:
    Chief Financial Officer

cc:   Leslie Marlow, Blank Rome LLP

United States securities and exchange commission logo
November 3, 2023
Marc Banjak
General Counsel
iBio, Inc.
8800 HSC Parkway
Bryan, Texas 77807
Re:iBio, Inc.
Registration Statement on Form S-3
Filed October 27, 2023
File No. 333-275204
Dear Marc Banjak:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Tamika Sheppard at 202-551-8346 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Leslie Marlow

CORRESP
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August 9, 2023

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    iBio, Inc.

    Registration Statement on Form S-1

    File No: 333-273749

    Request for Acceleration

Ladies and Gentlemen:

iBio, Inc. (the “Registrant”)
hereby requests that the Staff of the United States Securities and Exchange Commission (the “Commission”) take appropriate
action to cause the above-referenced Registration Statement on Form S-1 (File No. 333-273749) to become effective on Friday,
August 11, 2023, at 4:00 p.m., Eastern Time, or as soon thereafter as is practicable.

The
Registrant understands that the Staff of the Commission will consider this request as confirmation by the Registrant that it is aware
of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration
Statement.

The Registrant hereby authorizes
its counsel, Leslie Marlow, Esq. or Patrick J. Egan, Esq. of Blank Rome LLP, to orally modify or withdraw this request for acceleration.
Please contact Ms. Marlow at (212) 885-5358 or Mr. Egan at (212) 885-5346 with any questions you may have concerning this request,
and please notify either Ms. Marlow or Mr. Egan when this request for acceleration has been granted.

    Very truly yours,

    IBIO, INC.

    By:
    /s/ Felipe Duran

    Name: Felipe Duran

Title: Chief Financial Officer

    cc:

    Leslie Marlow, Esq., Blank Rome LLP

    Patrick J. Egan, Esq., Blank Rome LLP

United States securities and exchange commission logo
August 9, 2023
Martin Brenner, Ph.D.
Chief Executive Officer
iBio, Inc.
8800 HSC Parkway
Bryan, TX 77807
Re:iBio, Inc.
Registration Statement on Form S-1
Filed August 7, 2023
File No. 333-273749
Dear Martin Brenner:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Tyler Howes at 202-551-3370 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Leslie Marlow, Esq.

United States securities and exchange commission logo
December 3, 2020
Thomas F. Isett
Chairman and Chief Executive Officer
iBio, Inc.
8800 HSC Parkway
Bryan, Texas 77807-1107
Re:iBio, Inc.
Registration Statement on Form S-3
Filed November 25, 2020
File No. 333-250973
Dear Mr. Isett:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Chris Edwards at 202-551-6761 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Leslie Marlow, Esq.

CORRESP
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December 3, 2020

VIA EDGAR

United States Securities

    and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    iBio, Inc.

Registration Statement
on Form S-3

File No: 333-250973

Ladies and Gentlemen:

iBio, Inc. (the “Registrant”)
hereby requests that the United States Securities and Exchange Commission (the “Commission”) take appropriate
action to cause the above-referenced Registration Statement on Form S-3 (File No. 333-250973), to become effective on Monday,
December 7, 2020, at 9:00 a.m., Eastern Time, or as soon thereafter as is practicable.

The Registrant
hereby authorizes its counsel, Leslie Marlow, Esq. or Patrick J. Egan, Esq. of Gracin & Marlow, LLP, to orally modify or
withdraw this request for acceleration. Please contact Ms. Marlow at (516) 496-2223 or (212) 907-6457 or Mr. Egan at (914)
557-5574 or (212) 907-6457 with any questions you may have concerning this request, and please notify her when this request
for acceleration has been granted.

    Sincerely,

    /s/ Thomas F. Isett

    Thomas F. Isett

    Chief Executive Officer

     cc:
    Leslie Marlow, Esq.

    Patrick J. Egan, Esq.

    8800 HSC PARKWAY, BRYAN, TX, 77807 TEL: (979) 446-0027 WWW.IBIOINC.COM

CORRESP
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March 19, 2020

VIA EDGAR

Mr. Joseph McCann, Legal Branch Chief

Mr. Paul Fischer, Staff Attorney

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

 Re: iBio, Inc.

Registration Statement on Form S-3

File No. 333-236735

Gentlemen:

Pursuant to Rule 461 promulgated under
the Securities Act of 1933, as amended, iBio, Inc. (the “Registrant”) hereby requests acceleration of the effective
date of its Registration Statement on Form S-3 (File No. 333-236735), as amended (the “Registration Statement”), so
that it may become effective at 4:00 p.m. Eastern Daylight Time on March 19, 2020, or as soon as practicable thereafter.

If this request is granted, we respectfully
request that we be notified by telephone at the time of effectiveness and that such effectiveness also be confirmed in writing.
Please call Andrew Abramowitz of Andrew Abramowitz PLLC at 1 (212) 972-8882.

    Best Regards,

    iBio, Inc.

    By:
    /s/ Thomas F. Isett

    Name: Thomas F. Isett
Title: Chief Executive Officer and Executive Co-Chairman

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March 13, 2020

VIA EDGAR

Mr. Joseph McCann, Legal Branch Chief

Mr. Paul Fischer, Staff Attorney

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

 Re: iBio, Inc.

Registration Statement on Form S-3

Filed February 28, 2020

File No. 333-236735

Gentlemen:

On behalf of iBio, Inc. (the “Company”
or “iBio”), set forth below is our response to the comments raised by the Staff of the Securities and Exchange Commission
(the “Commission”) in its letter dated March 10, 2020 regarding the Company’s Registration Statement on Form
S-3 (the “Form S-3”).  For the Commission’s convenience, the Company has included the text of the comments
below with the Company’s response immediately following.

Coverpage

1.            Comment:
It appears that you are relying on General Instruction I.B.6 of Form S-3. If true, please revise your prospectus cover page to
disclose the calculation of the aggregate market value of your outstanding voting and nonvoting common equity and the amount of
all securities offered pursuant to General Instruction I.B.6 during the prior 12 calendar month period that ends on, and includes,
the date of the prospectus. Refer to Instruction 7 to General Instruction I.B.6. Otherwise, please provide us your analysis demonstrating
your eligibility to use Form S-3.

Response:  Please
be advised that we are not relying on General Instruction I.B.6 of Form S-3. As of February 28, 2020, the filing date of the
Form S-3, the aggregate market value of iBio’s outstanding common stock held by non-affiliates was approximately
$76,871,281 based on 97,091,972 shares of outstanding common stock, of which 8,734,177 shares were held by affiliates, at a
price of $0.87 per share, which was the last reported trading price of iBio’s common stock on NYSE American on February
27, 2020. Furthermore, as of March 13, 2020, the filing date of Amendment
No. 1 to the Form S-3, the aggregate market value of iBio’s outstanding common stock held by non-affiliates was approximately
$132,421,925 based on 101,336,922 shares of outstanding common stock, of which 8,734,177 shares were held by affiliates, at a price
of $1.43 per share, which was the last reported trading price of iBio’s common stock on NYSE American on March 12, 2020.

Description of Debt Securities, page
10

2.            Comment:
We note that you are registering debt securities and that the prospectus and legal opinion reference indentures. Please amend
your registration statement to file a form of indenture as an exhibit to your filing. For further guidance, refer to Interpretation
201.02 and 201.04 of our Trust Indenture Act of 1939 Compliance and Disclosure Interpretations.

Response:
We have elected not to register debt securities and have amended the Form S-3 and revised our prospectus to remove all references
to debt securities.

      1

General

3.            Comment:
We refer to your February 3, 2020 press release concerning your collaboration with Beijing CC-Pharming Ltd. to develop and
test a new 2019-nCoV vaccine to be manufactured using your FastPharming System (TM). Accordingly, please revise the prospectus
to address corporate developments concerning the coronavirus, or explain why this information is not material to investors. In
addition, please disclose the material terms of the collaboration agreement referenced in your February 3 press release and file
it as an exhibit to your filing, or explain why it is not material to an investment decision.

Response: The
Master Joint Development Agreement (the “MJDA”) between the Company and Beijing CC-Pharming Ltd.
(“BCCP”), dated August 8, 2018 and the Statement of Work 2 (the “SOW”), dated as of February 6, 2020,
have been filed as exhibits to our Current Report on Form 8-K, which was filed with the Commission on March 13, 2020 (the
 “Form 8-K”) and is incorporated by reference in Amendment No. 1 to the Form S-3. Certain information that is not
material to the Company was redacted because it would cause competitive harm to the Company if publicly disclosed. The
redacted material includes technical information and matters of proprietary business strategy.

The Company’s
normal business includes development of biopharmaceuticals for its own account and work for or collaboration with other parties
for the development, testing and manufacture of biopharmaceuticals, both preventive and therapeutic, against diseases. The relationship
with BCCP began in 2018 and initially focused on the development of an oncology biosimilar or bio-better drug and license and transfer
of the Company’s proprietary technology for drug development and manufacture to BCCP for use only in China. The two companies
also began evaluation and planning to eventually add additional product candidates to their collaboration to jointly develop additional
commercial opportunities. When the coronavirus problems emerged in China, BCCP sought to extend the collaboration with the Company
to development and testing of coronavirus vaccine candidates. BCCP was aware that the Company’s technology and facility were
designed to rapidly address threats from pandemic diseases and bioterrorism. As disclosed in the February 3, 2020 press release
issued by the Company, BCCP and the Company entered into a collaboration on the development and testing of vaccine candidates against
coronavirus that was rapidly spreading in China. Although the contemplated collaborative effort has just begun and not yet progressed
in any material respect, the Company’s separate activities have resulted in the development of possible vaccine candidates
based upon the Company’s own technology and its proprietary adjuvant. Four provisional patents for those candidates were
filed in the United States on March 11, 2020, which was also disclosed on the Form 8-K.

***

We are available to discuss our responses
to the SEC’s comments at any time.  Should there be any questions regarding our response or should the Staff require
any additional information, I can be reached at (302) 355-0650.

Sincerely,

iBio, Inc.

    By:
    /s/
    Thomas F. Isett

    Name:

    Thomas F. Isett

    Title:

    Chief Executive Officer and Executive Co-Chairman

      2

March 10, 2020
Robert B. Kay
Chief Executive Officer
iBio, Inc.
600 Madison Avenue, Suite 1601
New York, New York 10022
Re:iBio, Inc.
Registration Statement on Form S-3
Filed February 28, 2020
File No. 333-236735
Dear Mr. Kay:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-3 filed on February 28, 2020
Coverpage
1.It appears that you are relying on General Instruction I.B.6 of Form S-3. If true, please
revise your prospectus cover page to disclose the calculation of the aggregate market
value of your outstanding voting and nonvoting common equity and the amount of all
securities offered pursuant to General Instruction I.B.6 during the prior 12 calendar month
period that ends on, and includes, the date of the prospectus. Refer to Instruction 7 to
General Instruction I.B.6. Otherwise, please provide us your analysis demonstrating your
eligibility to use Form S-3.

 FirstName LastNameRobert B. Kay
 Comapany NameiBio, Inc.
 March 10, 2020 Page 2
 FirstName LastName
Robert B. Kay
iBio, Inc.
March 10, 2020
Page 2
Description of Debt Securities, page 10
2.We note the you are registering debt securities and that the prospectus and legal opinion
reference indentures.  Please amend your registration statement to file a form of indenture
as an exhibit to your filing. For further guidance, refer to Interpretations 201.02 and
201.04 of our Trust Indenture Act of 1939 Compliance and Disclosure Interpretations.
General
3.We refer to your February 3, 2020 press release concerning your collaboration with
Beijing CC-Pharming Ltd. to develop and test a new 2019-nCoV vaccine to be
manufactured using your FastPharming System(TM). Accordingly, please revise the
prospectus to address corporate developments concerning the coronavirus, or explain why
this information is not material to investors. In addition, please disclose the material terms
of the collaboration agreement referenced in your February 3 press release and file it as an
exhibit to your filing, or explain why it is not material to an investment decision.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Paul Fischer, Staff Attorney, at 202-551-3415, or Joseph McCann, Legal
Branch Chief,  at 202-551-6262, with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Andrew Abramowitz, Esq.

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A.G.P./Alliance Global Partners

590 Madison Avenue

New York, New York 10022

October 24, 2019

VIA EDGAR

U.S. Securities and Exchange Commission

100 F St., NE

Washington, D.C. 20549

    RE:
    iBio, Inc. (the “Company”)

    File No. 333-233504

    Registration Statement on Form S-1

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules
and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, A.G.P./Alliance Global
Partners, as representative of the underwriters, hereby joins the request of the Company that the effective date of the above-referenced
Registration Statement be accelerated so that it will become effective at 4:15 p.m. Eastern Time on October 24, 2019, or as soon
thereafter as practicable.

Pursuant to Rule 460 under the Securities
Act, please be advised that there will be distributed to each underwriter, who is reasonably anticipated to be invited to participate
in the distribution of the securities, as many copies of the proposed form of preliminary prospectus as appears to be reasonable
to secure adequate distribution of the preliminary prospectus.

The undersigned confirms that it has complied
with and will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied
with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the
above-referenced issue.

    Very truly yours,

    A.G.P./Alliance Global Partners

    By: Thomas Higgins

    /s/ Thomas Higgins

    Name: Thomas Higgins

    Title: Managing Director

CORRESP
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IBIO, INC.

600 Madison Avenue, Suite 1601

New York, NY 10022-1737

VIA EDGAR

October 24, 2019

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    RE:
    iBio, Inc.

    Registration Statement on Form S-1 (File No. 333-233504)

    Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461,
iBio, Inc. (the “Company”) hereby requests the Securities and Exchange Commission to accelerate the effective date
of the above-referenced Registration Statement and declare the Registration Statement effective as of 4:15 p.m. Eastern Time on
Thursday, October 24, 2019, or as soon thereafter as practicable.

    Sincerely,

    IBIO, INC.

    By:
    /s/ Robert B. Kay

    Name:  Robert B. Kay

    Title:  Executive Chairman and Chief Executive Officer

September 5, 2019
Robert B. Kay
Chief Executive Officer
iBio, Inc.
600 Madison Avenue, Suite 1601
New York, NY 10022-1737
Re:iBio, Inc.
Registration Statement on Form S-1
Filed August 28, 2019
File No. 333-233504
Dear Mr. Kay:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Christine Westbrook at 202-551-5019 with any questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance
cc:       Andrew Abramowitz, Esq.

CORRESP
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IBIO, INC.

600 Madison Avenue, Suite 1601

New York, NY 10022-1737

VIA EDGAR

June 20, 2018

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention:

 RE: iBio, Inc.

Registration Statement on Form S-1
(File No. 333-224620)

Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461,
iBio, Inc. (the “Company”) hereby requests the Securities and Exchange Commission to accelerate the effective date
of the above-referenced Registration Statement and declare the Registration Statement effective as of 5:00 p.m., Washington, D.C.
time, on Thursday, June 21, 2018 or as soon thereafter as practicable.

    Sincerely,

    IBIO, INC.

    By:
    /s/ Robert B. Kay

    Name:
    Robert B. Kay

    Title:
    Executive Chairman and Chief Executive Officer

CORRESP
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A.G.P./Alliance Global Partners

590 Madison Avenue

New York, New York 10022

June 20, 2018

VIA EDGAR

U.S. Securities and Exchange Commission

100 F St., NE

Washington, D.C. 20549

 RE: iBio, Inc. (the “Company”)

File No. 333-224620

Registration Statement on Form S-1

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules
and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, A.G.P./Alliance Global
Partners, as representative of the underwriters, hereby joins the request of the Company that the effective date of the above-referenced
Registration Statement be accelerated so that it will become effective at 5:00 p.m. Eastern Time on June 21, 2018, or as soon thereafter
as practicable.

Pursuant to Rule 460 under the Securities
Act, please be advised that there will be distributed to each underwriter, who is reasonably anticipated to be invited to participate
in the distribution of the securities, as many copies of the proposed form of preliminary prospectus as appears to be reasonable
to secure adequate distribution of the preliminary prospectus.

The undersigned confirms that it has complied
with and will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied
with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the
above-referenced issue.

    Very truly yours,

    A.G.P./Alliance Global Partners

    By: /s/ Thomas Higgins

    Name: Thomas Higgins

    Title: Managing Director

May 10, 2018
Robert Kay
Chief Executive Officer
iBio, Inc.
600 Madison Avenue, Suite 1601
New York, NY 10022-1737
Re:iBio, Inc.
Registration Statement on Form S-1
Filed May 2, 2018
File No. 333-224620
Dear Mr. Kay:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Dorrie Yale at 202-551-8776 with any questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc:       Andrew Abramowitz

August 9, 2017
Robert B. Kay
Chief Executive Officer
iBio, Inc.
600 Madison Avenue, Suite 1601
New York, NY 10022
iBio, Inc.
Registration Statement on Form S-1
Filed August 4, 2017
File No. 333-219725Re:
Dear Mr. Kay:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contact Ada D. Sarmento at (202) 551-3798 with any questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Andrew Abramowitz, Esq.

CORRESP
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IBIO, INC.

600 Madison Avenue, Suite 1601

New York, NY 10022-1737

VIA EDGAR

August 10, 2017

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention:

    RE:
    iBio, Inc.

    Registration Statement on Form S-1 (File No. 333-219725)

    Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461,
iBio, Inc. (the “Company”) hereby requests the Securities and Exchange Commission to accelerate the effective date
of the above-referenced Registration Statement and declare the Registration Statement effective as of 4:30 p.m., Washington, D.C.
time, on Friday, August 11, 2017 or as soon thereafter as practicable.

    Sincerely,

    IBIO, INC.

    By:
    /s/ Robert B. Kay

    Name:
    Robert B. Kay

    Title:
    Executive Chairman and Chief Executive Officer

CORRESP
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    Unassociated Document

IBIO, INC.

9 Innovation Way, Suite 100

Newark, Delaware 19711

VIA EDGAR

July 27, 2011

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention:  Jeffrey Riedler, Esq. and Scot Foley, Esq.

RE:

iBio, Inc.

Registration Statement on Form S-3 (File No. 333-175420)

Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461, iBio, Inc. (the “Company”) hereby requests the Securities and Exchange Commission to accelerate the effective date of the above-referenced Registration Statement and declare the Registration Statement effective as of 4:00 p.m., Washington, D.C. time, on Thursday, July 28, 2011 or as soon thereafter as practicable.

The Company hereby acknowledges that:

·

should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

·

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

·

the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely,

IBIO, INC.

By:

/s/ Douglas Beck

Name:

Douglas Beck

Title:

Chief Financial Officer

cc:  Robert B. Kay

July 19, 2011
 Via E-mail

Robert B. Kay Chief Executive Officer iBio, Inc.  9 Innovation Way, Suite 100 Newark, Delaware 19711
Re: iBio, Inc.
  Registration Statement on Form S-3
Filed July 8, 2011
  File No. 333-175420

Dear Mr. Kay:
 We have limited our review of your registrati on statement to the issue we have addressed
in our comment.  Please respond to this lette r by amending your registration statement as
requested.  If you do not believe our  comment applies to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in a response.
 After reviewing any amendment to your re gistration statement or any information you
provide in response to this comment, we may have additional comments.
 Information Incorporated by Reference, page 36

1. Please amend your registration statement to include among the documents you are
incorporating by reference the Current Repor t on Form 8-K that you filed on June 23,
2011.   We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Notwithstanding our comment, in the event you request acceleration of the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

Robert B. Kay  iBio, Inc.  July 19, 2011 Page 2

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.  Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.
 Please contact Scot Foley at (202) 551- 3383 or me at (202) 551-3715 with any other
questions.
Sincerely,
   /s/ Jeffrey Riedler
Jeffrey Riedler Assistant Director
  cc: Andrew Abramowitz, Esq.
Andrew Abramowitz, PLLC 565 Fifth Avenue 9
th Floor
New York, New York 10017

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IBIO, INC.

9 Innovation Way, Suite 100

Newark, Delaware 19711

VIA
EDGAR

March 17, 2011

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Jeffrey Riedler, Esq. and Karen Ubell, Esq.

    RE:

    iBio,
    Inc.

    Registration Statement on Form S-3 (File No. 333-171315)

    Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule
461, iBio, Inc. (the “Company”) hereby requests the Securities and Exchange Commission to accelerate the effective
date of the above-referenced Registration Statement and declare the Registration Statement effective as of 4:00 p.m., Washington,
D.C. time, on Friday, March 18, 2011 or as soon thereafter as practicable.

The Company hereby
acknowledges that:

    ·
    should the Commission or the staff, acting
        pursuant to delegated authority, declare the filing effective, it does
        not foreclose the Commission from taking any action with respect to the
    filing;

    ·
    the
          action of the Commission or the staff, acting pursuant to delegated
          authority, in declaring the filing effective, does not relieve the
          Company from its full responsibility for the adequacy and accuracy
    of the disclosure in the filing; and

    ·
    the Company may not asser this action as a defense in any proceeding initiated by the Commission
    or any person under the federal securities laws of the United States.

Sincerely,

IBIO, INC.

By: /s/ Frederick Larcombe

Name: Frederick Larcombe

Title: Chief Financial Officer

cc: Robert B. Kay

March 11 , 2011

Frederick Larcombe
Chief Financial Officer
iBio, Inc.
9 Innovation Way, Suite 100
Newark, DE  19711

Re: iBio, Inc.
  Amendment No. 2 to Registration Statement on Form S -1 on Form S -3
Filed  March 7 , 2011
  File No.  333-171315

Dear Mr. Larcombe:

We have reviewed your amended filing and your response letter each dated March 7 ,
2011 and have the following comment.  In  our comment, we ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter by amendin g your registration statement and providing the
requested information .  Where you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to this comments, we may have  additional comments.

Plan of Distribution, page 17

1. We note your response to our February 23, 2011 letter and your revised disclosure in
your amended filing and  reissue our comment in part.  Please expand your disclosure on
page 18 under the heading “Plan of Distribution” to specifically identify Messrs. Kay and
DeSantis, Kobus Investments, LLC and BioMed Investments, LLC  as underwriters.  As
Messrs. Kay and DeSa ntis, Kobus Investments, LLC and BioMed Investments, have been
determined to be underwriters engaged in a distribution, it is not appropriate to disclose
that, as with the other selling stockholders, they “may be deemed” to be underwriters.

We urge al l persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its manage ment are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Frederick Larcombe
iBio, Inc.
March 11 , 2011
Page 2

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and th e Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
regist ration statement.

You may contact Karen Ubell at (202) 551 -3873 or me at (202) 551 -3715  with any other
questions.

Sincerely,

Jeffrey Riedler
Assistant Director

cc: Andrew Abramowitz, Esq.
Andrew Abramowitz, PLLC
565 Fifth Avenue, 9th Floor
New York, NY  10017

February 23, 2011

Frederick Larcombe Chief Financial Officer iBio, Inc. 9 Innovation Way, Suite 100 Newark, DE  19711
Re: iBio, Inc.
  Amendment No. 1 to Registration Statement on Form S-1 on Form S-3
Filed January 27, 2011
  File No. 333-171315

Dear Mr. Larcombe:
 We have reviewed your your response le tter dated February 16, 2011 and have the
following comment.
 Please respond to this letter by amending your registration statement and providing the
requested information.  Where you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to this comments, we may have additional comments.

General

1. Please expand your disclosure on page 17 under the heading “Plan of  Distribution” to
specifically identify Messrs. Kay and DeSa ntis, Kobus Investments, LLC and BioMed
Investments, LLC as underwriters.  As it curre ntly reads, you have not differentiated the
other selling stockholders from Messrs. Kay and DeSantis, Kobus Investments, LLC and BioMed Investments, LLC each of which have  been determined to be underwriters.
Further, please identify the material relationship between you and each of the
underwriters.  This disclosure should include the description of th e arrangements made
by the company to facilitate and encourage th e sale of the options from Messrs. Kay and
DeSantis to Kobus Investments, LLC and BioM ed Investments, LLC as described in your
January 27 response letter.  Your discussion should also disclose any commissions, fees
or proceeds to be earned by or  paid to Messrs. Kay or DeSantis pursuant to the sale or
exercise of the options.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and

Frederick Larcombe iBio, Inc. February 23, 2011 Page 2

all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the registration statement.
 You may contact Karen Ubell at (202) 551-3873, Dan Greenspan at (202) 551-3623 or
me at (202) 551-3715 with any other questions.
Sincerely,

Jeffrey Riedler
Assistant Director

cc: Andrew Abramowitz, Esq.
Andrew Abramowitz, PLLC 565 Fifth Avenue, 9th Floor New York, NY  10017

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iBio, Inc.

9 Innovation Way, Suite 100

Newark, Delaware 19711

February 16, 2011

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

iBio,
Inc. (the “Company”)

Registration Statement on Form S-3

File No. 333-171315

Ladies and Gentlemen:

This letter is a
supplemental response to the comments received from the staff of the SEC by letters dated February 3, 2011 and February 10, 2011,
relating to the above-captioned registration statement (the “Registration Statement”).

To facilitate the
staff’s review, we have set forth the text of the single comment from each of the two letters in italics, followed by a single
response that addresses both comments. If the staff concurs with our proposed revisions to the Registration Statement described
in our response, we would promptly thereafter file Amendment No. 2 to the Registration Statement reflecting those revisions.

Comment of
February 3, 2011: We note your response to our prior comment 1. You have described why the registration of the resale
of 3,000,000 shares of common stock underlying stock options held by private investors to purchase shares currently held by E.
Gerald Kay and Carl DeSantis is desirable, but you have not provided a legal analysis supporting your conclusion that registration
of such shares is appropriate at this time. Accordingly, we reissue our comment. Please provide us with a detailed legal analysis
underlying your conclusion that it is appropriate under the federal securities laws to register the resale of these shares before
exercise of the option takes place and tell us why it is appropriate generally to register the resale of shares underlying an option
not issued by the registrant. Your analysis should identify the legal authority upon which you have relied in reaching your conclusion.
Alternatively, please revise your registration statement to remove these shares.

Comment of
February 10, 2011: We note your statement in your response to our prior comment 1 that "'The Company has encouraged
Messrs. Kay and DeSantis to

make some of their holdings available for purchase by others and has involved the option holders, affiliates
of the placement agent in the Company's recent private offering, to facilitate an efficient distribution of the shares to a variety
of other investors particularly including institutional investors." Based on your response, it appears that this transaction
is a primary distribution by or on behalf of the company. Accordingly, please revise your filing to register the shares on a form
on which you are eligible to conduct a primary offering and identify each of Messrs. Kay and DeSantis, Kobus Investments, LLC and
BioMed Investments, LLC as underwriters. Alternatively, please remove Kobus Investments, LLC and BioMed Investments, LLC and their
associated shares from the registration statement.

The Company concurs
with the staff’s view that the Kay/DeSantis option transaction is properly understood as a primary distribution by or on
behalf of the Company. In response to the staff’s comment, the Company proposes to amend the Registration Statement to identify
each of Messrs. Kay and DeSantis, Kobus Investments, LLC and BioMed Investments, LLC as underwriters, by revising a paragraph in
the Plan of Distribution section as follows (new language emphasized):

The selling stockholders and any
broker-dealers or agents that are involved in selling the shares, including, with respect to the option shares described
in this prospectus, E. Gerald Kay, Carl DeSantis, Kobus Investments, LLC and BioMed Investments, LLC, may be deemed to
be “underwriters” within the meaning of the Securities Act in connection with such sales. In such event, any commissions
received by such broker-dealers or agents and any profit on the resale of the shares purchased by them may be deemed to be underwriting
commissions or discounts under the Securities Act. Discounts, concessions, commissions and similar selling expenses, if any, that
can be attributed to the sale of Securities will be paid by the selling stockholder and/or the purchasers. Each selling stockholder
has represented and warranted to us that it acquired the securities subject to this registration statement in the ordinary course
of such selling stockholder’s business and, at the time of its purchase of such securities such selling stockholder had no
agreements or understandings, directly or indirectly, with any person to distribute any such securities.

The amendment to
the Registration Statement would also contain appropriate changes not relating directly to the staff’s comments, such as
including the Company’s recently filed Quarterly Report on 10-Q in the Information Incorporated by Reference section and
other non-substantive changes such as dates.

The letter that
accompanied the Company’s filing of Amendment No. 1 to the Registration Statement contained an analysis of the Company’s
eligibility to use Form S-3. That analysis was predicated on the entire offering being deemed a secondary offering, before being
advised of the staff’s view that the resale of shares underlying the Kay/DeSantis option should be deemed to be a primary
offering. However, the Company has concluded that it remains eligible for the use of Form S-3 for the entire offering. With respect
to all of the shares included in the Registration Statement other than the option shares, the Company continues to rely on General
Instruction I.B.3. to Form S-3

2

(Transactions Involving Secondary Offerings), as detailed in the letter that accompanied the Company’s
filing of Amendment No. 1 to the Registration Statement. With respect to the option shares, the Company is separately eligible
to use Form S-3 for primary offerings pursuant to General Instruction I.B.1. to Form S-3 (Primary Offerings by Certain Registrants),
which is available for securities offered for cash by or on behalf of a registrant if the aggregate market value of the voting
and non-voting common equity held by non-affiliates of the registrant is $75 million or more. Based on the closing price of the
Company’s common stock on February 14, 2011 ($4.20), the market value of the 22,390,786 shares that are currently held by
non-affiliates would be $94,041,301, above the necessary threshold.

Concluding
Notes

A request for acceleration
of the effectiveness of the Registration Statement will be submitted by the Company as soon as the SEC has reviewed this letter
and the next amendment to the Registration Statement and has advised the Company that no further issues remain outstanding. At
the time of the request, the Company will furnish a letter acknowledging the SEC’s position with respect to declaration of
effectiveness and staff comments.

Should any member
of the SEC’s staff have any questions concerning the enclosed materials or desire any further information or clarification
in respect of the Registration Statement, please do not hesitate to contact me at (609) 802-6466, or our counsel, Andrew Abramowitz,
at (212) 972-8882.

Very truly yours,

/s/ Frederick Larcombe

iBio, Inc.

Frederick Larcombe

Chief Financial Officer

Enclosures

cc:

Jeffrey
Riedler, Esq.

Assistant Director, Division of Corporation Finance

Karen Ubell, Esq.

Staff Attorney, Division of Corporation Finance

Mr. Robert B. Kay

3

February 10, 2011

Frederick Larcombe Chief Financial Officer iBio, Inc. 9 Innovation Way, Suite 100 Newark, DE  19711
Re: iBio, Inc.
  Amendment No. 1 to Registration Statement on Form S-1 on Form S-3
Filed January 27, 2011
  File No. 333-171315

Dear Mr. Larcombe:
 We have reviewed your amended filing and your response letter each dated January 27,
2011 and have the following comment.
 Please respond to this letter by amending your registration statement and providing the
requested information.  Where you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to this comments, we may have additional comments.

General

1. We note your statement in your response to our prior comment 1 that “The Company has
encouraged Messrs. Kay and DeSantis to ma ke some of their holdings available for
purchase by others and has involved the option ho lders, affiliates of the placement agent
in the Company’s recent private offering, to f acilitate an efficient distribution of the
shares to a variety of other investors particul arly including institutional investors.”  Based
on your response, it appears that this transaction is a primar y distribution by or on behalf
of the company.  Accordingly, please revise you r filing to register the shares on a form on
which you are eligible to conduct a primary offering and identify each of Messrs. Kay and DeSantis, Kobus Investments, LLC and Bi oMed Investments, LLC as underwriters.
Alternatively, please remove Kobus Investments, LLC and BioMed Investments, LLC and their associated shares from the registration statement.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in

Frederick Larcombe iBio, Inc. February 10, 2011 Page 2

possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the registration statement.
 You may contact Karen Ubell at (202) 551-3873, Dan Greenspan at (202) 551-3623 or
me at (202) 551-3715 with any other questions.
Sincerely,

Jeffrey Riedler Assistant Director

cc: Andrew Abramowitz, Esq.
Andrew Abramowitz, PLLC
565 Fifth Avenue, 9th Floor New York, NY  10017

February 3, 2011

Frederick Larcombe Chief Financial Officer iBio, Inc. 9 Innovation Way, Suite 100 Newark, DE  19711
Re: iBio, Inc.
  Amendment No. 1 to Registration Statement on Form S-1 on Form S-3
Filed January 27, 2011
  File No. 333-171315

Dear Mr. Larcombe:
 We have reviewed your amended filing and your response letter each dated January 27,
2011 and have the following comment.  In our comment, we ask you to provide us with
information so we may better understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  Where you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to this comments, we may have additional comments.

General

1. We note your response to our prior comment 1.  You have described why the registration
of the resale of 3,000,000 shares of comm on stock underlying stock options held by
private investors to purchase shares currently held by E. Gerald Kay and Carl DeSantis is
desirable, but you have not provided a lega l analysis supporting your conclusion that
registration of such shares is appropriate at this time.  Accordingly, we reissue our
comment.  Please provide us with a detailed  legal analysis under lying your conclusion
that it is appropriate under the federal securities  laws to register the resale of these shares
before exercise of the option takes place and tell us why it is appropriate generally to
register the resale of shares  underlying an option not issued  by the registrant.  Your
analysis should identify the legal authority  upon which you have relied in reaching your
conclusion.  Alternatively, please revise your  registration statement to remove these
shares.

Frederick Larcombe iBio, Inc. February 3, 2011 Page 2

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the registration statement.
 You may contact Karen Ubell at (202) 551-3873 or me at (202) 551-3715 with any other
questions.
Sincerely,

Jeffrey Riedler
Assistant Director
cc: Andrew Abramowitz, Esq.
Andrew Abramowitz, PLLC 565 Fifth Avenue, 9th Floor New York, NY  10017

January 7, 2011

Robert B. Kay Chief Executive Officer iBio, Inc. 9 Innovation Way, Suite 100 Newark, DE  19711
Re: iBio, Inc.
  Registration Statement on Form S-1
Filed December 21, 2010
  File No. 333-171315

Dear Mr. Kay:
 We have limited our review of your registra tion statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  Where you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.

General

1. We note that you are proposing to regist er the resale of 3,000,000 shares of common
stock underlying stock options held by private in vestors to purchase sh ares currently held
by E. Gerald Kay and Carl DeSantis.  Please provide us with a detailed analysis underlying your conclusion that it is appropriate to register the resale of these shares
before exercise of the option takes place and tell us why it is appropriate generally to
register the resale of shar es underlying an option not issued by the registrant.
Alternatively, please revise your registration statement to  remove these shares.

2. Please clarify the beneficial owner(s ) of the 3,000,000 shares of common stock
underlying stock options being registered.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in

Robert B. Kay iBio, Inc. January 7, 2011 Page 2

possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:

• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

• the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.  Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the registration statement.
 You may contact Karen Ubell at (202) 551-3873 or me at (202) 551-3715 with any other
questions.
Sincerely,

Jeffrey Riedler Assistant Director
cc: Andrew Abramowitz, Esq.
Andrew Abramowitz, PLLC 565 Fifth Avenue, 9th Floor New York, NY  10017

November 10, 2010

Mr. Robert B. Kay Executive Chairman and Chief Executive Officer iBio, Inc. 9 Innovation Way, Suite 100 Newark, DE 19711
Re: iBio, Inc.  Form PRE 14A
Filed October 28, 2010 File No. 000-53125
 Dear Mr. Kay:

 We have completed our review of the above listed filing and have no further comments at this time.
Sincerely,
       Jeffrey P. Riedler
Assistant Director

CORRESP
1
filename1.htm

Andrew Abramowitz

212-972-8882

E-mail: aa@aalegalnyc.com

November 8, 2010

VIA EDGAR

Mr. Jeffrey P. Riedler

Assistant Director

-and-

Ms. Rose Zukin

Staff Attorney

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

            Re:

            iBio, Inc. – Preliminary Proxy Statement (PRE 14A)

  filed October 28, 2010 (No. 000-51325)

Dear Mr. Riedler and Ms. Zukin:

On behalf of iBio, Inc., a Delaware corporation (the “Company”), I am responding to your letter of November 5, 2010 regarding the above-captioned filing made by the Company (the “Preliminary Proxy”).

The Company proposes to revise the disclosure in the second paragraph of Proposal 3, on page 14 of the Preliminary Proxy, in response to the Staff’s comment.  Below is the original language of this paragraph, followed by the Company’s proposed revision:

Original Language:

The additional shares of common stock that we are seeking authorization for may be used for such corporate purposes as the Board of Directors may determine from time to time to be necessary or desirable. These purposes may include, without limitation: raising capital through the sale of common stock; acquiring other businesses in exchange for shares of common stock; and attracting and retaining employees by the issuance of additional securities under our incentive compensation plan and other employee equity compensation arrangements.

Revised Language:

We do not have any plans, arrangements or understandings for the newly authorized but unissued shares that will be available following the increase in authorized shares.  However, the additional shares of common stock that we are seeking authorization for may be used for such corporate purposes as the Board of Directors may determine from time to time to be necessary or desirable. These purposes may include, without limitation: raising capital through the sale of common stock; acquiring other businesses in exchange for shares of common stock; and attracting and retaining employees by the issuance of additional securities under our incentive compensation plan and other employee equity compensation arrangements.

On behalf of the Company, I hereby confirm that the Company acknowledges that:

•             the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•             staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

•             the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

*       *      *

Kindly address any comments or questions that you may have concerning this letter to me at (212) 972-8882.  The Company expected to file a definitive version of its proxy statement this coming Wednesday, November 10, to meet its planned annual meeting schedule, and we would therefore greatly appreciate an expedited review of the proposed revised disclosure.

Very truly yours,

/s/ Andrew Abramowitz

Andrew Abramowitz

            cc:

            Mr. Robert B. Kay

2

November 5, 2010

Mr. Robert B. Kay Executive Chairman and Chief Executive Officer iBio, Inc. 9 Innovation Way, Suite 100 Newark, DE 19711
Re: iBio, Inc.  Form PRE 14A
Filed October 28, 2010 File No. 000-53125
 Dear Mr. Kay:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Preliminary Proxy Statement on Schedule 14A

1. Please disclose whether you currently have, or do not have, any plans to issue any of the
authorized but unissued shares that would be available as a result of the approval of the
amendment to the Certificate of Incorporation to increase the number of authorized
shares of common stock from 50,000,000 to 100,000,000 shares.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:

Mr. Robert B. Kay
iBio, Inc. November 5, 2010 Page 2

• the company is responsible for the adequacy and accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of  the United States.

You may contact Rose Zukin at (202) 551-3239 or me at ( 202) 551-3710 if you have any
questions.
Sincerely,
       Jeffrey P. Riedler
Assistant Director

July 16, 2008
 Mail Stop 6010
 Robert L. Erwin President InB:Biotechnologies, Inc. 9 Innovation Way, Suite 100 Newark, Delaware 19711
Re: InB:Biotechnologies, Inc.
 Registration Statement on Form 10-12G, filed July 11, 2008  File No. 0-53125

Dear Mr. Erwin:

We have reviewed your filing and have the following comments.  Where indicated, we
think you should revise your documents in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure.  After reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to working with you in these respects.  We welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10

Item 15.  Financial Statements and Exhibits

1. We note that the form of Securities Purchase Agreement filed as Exhibit 10.5 to the
Form 10 references a Registration Rights Agreement to be included as Exhibit B of the Securities Purchase Agreement.  Please revise Exhibit 10.5 to include the form of Registration Rights Agreement once available.

Robert L. Erwin
InB:Biotechnologies, Inc. July 16, 2008
Page 2

Exhibit 99.1 – Information Statement

Integrated Biopharma Schedule 14C
 iBioPharma, Inc. Unaudited Pro forma Financial Statements, page 34

 iBioPharma, Inc.  Notes to Unaudited Pro Forma Financial Statements, page 37

2. Please refer to Note (7).  Please expand your disclosure to explain why corporate support charges are significantly less for the nine months ended March 31, 2008 in proportion to charges for the year ended June 30, 2007.
 Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

 Results of Operations

 Selling and Administrative Expenses, pages 50 and 53

3. Please restore your disclosure that discusses the reason for significant changes in corporate support charges for each period.

* * * * *

As appropriate, please amend your filings in response to these comments.  You may wish
to provide us with marked copies of the amendment to expedite our review.  Please furnish a cover letter with your amendment that keys your response to our comment and provides any requested supplemental information.  Detailed cover letters greatly facilitate our review.  Please file your cover letter on EDGAR under the form type label CORRESP. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

Robert L. Erwin
InB:Biotechnologies, Inc. July 16, 2008 Page 3
 You may contact Ibolya Ignat at (202) 551-3656 or Donald Abbott at (202) 551-3608 if
you have questions regarding comments on the financial statements and related matters.  Please contact Sebastian Gomez Abero at (202) 551-3578 or Michael Reedich at (202) 551-3612 with any other questions.

        S i n c e r e l y ,              J e f f r e y  P .  R i e d l e r          A s s i s t a n t  D i r e c t o r    cc: Andrew H. Abramowitz, Esq.
Greenberg Traurig, LLP 200 Park Avenue New York, New York 10166