United States securities and exchange commission logo February 22, 2022 Michael S. Rosol, Ph.D. Chief Medical Officer Navidea Biopharmaceuticals, Inc. 4995 Bradenton Avenue, Suite 240 Dublin, Ohio 43017 Re: Navidea Biopharmaceuticals, Inc. Registration Statement on Form S-1 Filed February 14, 2022 File No. 333-262691 Dear Dr. Rosol: 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 Tim Buchmiller at (202) 551-3635 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: William M. Mower, Esq.