United States securities and exchange commission logo August 28, 2023 Russell Beyer Chief Financial Officer SAB Biotherapeutics, Inc. 2100 East 54th Street North Sioux Falls, SD 57104 Re: SAB Biotherapeutics, Inc. Registration Statement on Form S-3 Filed August 21, 2023 File No. 333-274119 Dear Russell Beyer: 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 Doris Stacey Gama at 202-551-3188 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Grant Levine, Esq.