November 8, 2019

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

       Re: Bionik Laboratories Corp.
           Registration Statement on Form S-1
           Response dated November 5, 2019
           File No. 333-233796

Dear Dr. Dusseux:

        We have reviewed your November 5, 2019 response to our comment letter
and have the
following comment. In our comment, 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 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 our comment, we may have additional comments.

Response Dated November 5, 2019

General

1.     We note that the disclosure proposed in your response indicates that the
choice of forum
       provision does not preclude or contract the scope of concurrent
jurisdiction for any actions
       brought under the Securities Act. This disclosure appears inconsistent
with your
       disclosure that your exclusive forum provision could apply to claims
under the Securities
       Act. Please reconcile your disclosures, and clearly disclose whether you
intend for the
       provision to apply to actions arising under the Securities Act. If the
provision applies to
       Securities Act claims, state in your prospectus that there is
uncertainty as to whether a
       court would enforce such provision.
 Eric Michel Dusseux
FirstName LastNameEric Michel Dusseux
Bionik Laboratories Corp.
November NameBionik Laboratories Corp.
Comapany 8, 2019
Page 2
November 8, 2019 Page 2
FirstName LastName
        Please contact Tim Buchmiller at (202) 551-3635 or Russell Mancuso,
Legal Branch
Chief, at (202) 551-3617 with any questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Life
Sciences
cc:      Stephen E. Fox, Esq.