United States securities and exchange commission logo





                          September 22, 2020

       Kenneth Carter, Ph.D.
       Executive Chairman
       Seneca Biopharma, Inc.
       20271 Goldenrod Lane, 2nd Floor
       Germantown, MD 20876

                                                        Re: Seneca Biopharma,
Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed September 16,
2020
                                                            File No. 333-248848

       Dear Dr. Carter:

              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.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              Raul Silvestre, Esq.