October 11, 2018

Eric Dusseux
Chief Executive Officer
Bionik Laboratories Corp.
483 Bay Street, N105
Toronto, ON M5G 2C9

       Re: Bionik Laboratories Corp.
           Post-Effective Amendment to Form S-1
           Filed September 21, 2018
           File No. 333-222236

Dear Mr. Dusseux:

       We have limited our review of your post-effective amendment 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.

Post-Effective Amendment to Form S-1

Cover Page

1.     We note you are attempting to register the resale of 33,613,063 common
shares that you
       issued as a result of anti-dilution provisions in the warrants you sold
as part of this
       offering. Please remove the resale of these shares from your
registration statement as
       Rule 416 applies to dilution resulting from stock splits, stock
dividends or similar
       transactions, not to anti-dilution provisions in warrants such as those
described here.
2.     We note your disclosure in the third paragraph of your Explanatory Note
indicating you
       are incorporating previous periodic reports into this registration
statement by reference.
       Please provide us your analysis of your eligibility to incorporate by
reference given
 Eric Dusseux
Bionik Laboratories Corp.
October 11, 2018
Page 2
      Instruction VII.D to Form S-1. If you are ineligible to incorporate by
reference, please
      revise to remove any suggestion to the contrary; ensure your registration
statement
      contains disclosure for all required items.
        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 Caleb French at 202-551-6947 or Geoff Kruczek, Senior
Attorney, at 202-
551-3641 with any questions.



                                                           Sincerely,
FirstName LastNameEric Dusseux
                                                           Division of
Corporation Finance
Comapany NameBionik Laboratories Corp.
                                                           Office of
Electronics and Machinery
October 11, 2018 Page 2
cc:       Stephen E. Fox, Esq.
FirstName LastName