Eleven fetal lambs were tested for auditory brain stem responses (ABRs) at 105 and 90 db sound pressure level from 110 to 116 days until 133 days gestation. ABRs were elicited in response to 1200 clicks, presented at 16 clicks/sec, from a hearing aid receiver secured in the fetal external ear canal and recorded from subdermal stainless steel electrodes at the vertex (active electrode) and anterior pinna (reference electrode). Six term newborn lambs were tested similarly for ABR comparison. No fetal ABRs appeared before 117 days gestation. Thereafter, the ABRs exhibited decreasing peak latencies with increasing stimulus intensity and fetal age. Newborn ABR latency measurements were compared with predicted newborn values generated from linear regression analysis of fetal data. Newborn latencies to waves I and II approximated predicted values. Newborn latencies to waves III, IV, and V were much shorter than predicted, suggesting rapid maturation of higher brain stem and midbrain neurogenerators during late fetal development.