A new model for seawater scattering was developed, in which Gibbs function was used exclusively to derive the thermodynamic parameters that are associated with density fluctuation. Because Gibbs function was determined empirically from highly accurate measurements of a group of thermodynamic variables and is valid for S(A) up to 120 g kg(-1) (Deep-Sea Research I, 55, 1639, 2008), we expect the model is also valid over the extended range of salinity. The model agrees with the measurements by Morel (Cahiers Oceanographiques, 20, 157, 1968) with an average difference of -0.6% for S = 0 and 2.7% for S = 38.4. The scattering by seawater as predicted increases with salinity in a non-linear fashion, and linear extrapolation of scattering based on Morel's measurements would overestimate by up to 30%. The extrapolation of ZHH09 model (Optics Express, 17, 5698, 2009), which is valid for S(A) up to 40 g kg(-1), however, agrees with the prediction within +/- 2.5% over the entire range of salinity. Even though there are no measurements available for validation, the results suggested that the uncertainty is limited in using the newly developed model in estimating the scattering by seawater of high salinity.