United States securities and exchange commission logo





                               May 27, 2020

       James Nathanielsz
       Chief Executive Officer
       Propanc Biopharma, Inc.
       302, 6 Butler Street
       Camberwell, VIC, 3124 Australia

                                                        Re: Propanc Biopharma,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed May 13, 2020
                                                            File No. 333-238240

       Dear Mr. Nathanielsz:

              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.

       Form S-1 filed May 13, 2020

       Cover Page

   1.                                                   Please revise your
disclosure here, page 39, pages 66 through 67, and throughout your
                                                        registration statement,
to clarify whether this is a primary offering of newly issued shares
                                                        or a secondary offering
of outstanding shares registered on behalf of a selling stockholder.
       Selling Stockholder, page 66

   2.                                                   Given the nature of the
offering and its size relative to the number of shares outstanding
                                                        held by non-affiliates,
it appears that the selling stockholder may be acting as a conduit for
                                                        the company in an
indirect primary offering. Please revise to identify the selling
                                                        stockholder as an
underwriter. Alternatively, provide an analysis of why you believe this
                                                        is not an indirect
primary offering, taking into consideration each of the factors identified
 James Nathanielsz
Propanc Biopharma, Inc.
May 27, 2020
Page 2
         in Securities Act Rules Compliance and Disclosure Interpretations
612.09, as well as any
         other factors you deem relevant. Please identity of the individual(s)
with dispositive and
         voting control over the Ionic Ventures shares in this analysis and
revise your disclosure as
         appropriate.
General

3.       Please update your financial statements and related disclosures for
the quarter ended
         March 31, 2020.
        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 Courtney Lindsay at (202) 551-7237 or Joseph McCann at
(202) 551-6262
with any questions.



FirstName LastNameJames Nathanielsz                            Sincerely,
Comapany NamePropanc Biopharma, Inc.
                                                               Division of
Corporation Finance
May 27, 2020 Page 2                                            Office of Life
Sciences
FirstName LastName