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                          June 30, 2020

       Joseph Truitt
       Chief Executive Officer
       BioSpecifics Technologies Corp.
       2 Righter Parkway, Suite 200
       Wilmington, DE 19803

                                                        Re: BioSpecifics
Technologies Corp.
                                                            Registration
Statement on Form S-3
                                                            Filed June 26, 2020
                                                            File No. 333-239484

       Dear Mr. Truitt:

              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:                                              Celia A. Soehner, Esq.