May 19, 2009

VIA EDGAR

Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

Re: Escalon Medical Corp.
File No. 333-157174
Registration Statement on Form S-3

Ladies and Gentlemen:

     Pursuant to Rule 461 under the Securities Act of 1933, Escalon Medical Corp. (the “Company”) hereby requests that the effective date of the Company’s Registration Statement on Form S-3 (File No. 333-157174) be accelerated to 9 a.m. on Thursday, May 21, 2009, or as soon thereafter as practicable. The Company hereby acknowledges that:

• Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

• The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

• The Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely, ESCALON MEDICAL CORP.
By:	/s/ Richard J. DePiano
	Richard J. DePiano,
	Chairman of the Board