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                             July 7, 2020

       Joseph Moscato
       Chief Executive Officer
       Generex Biotechnology Corporation
       10102 USA Today Way
       Miramar, FL 33025

                                                        Re: Generex
Biotechnology Corporation
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed June 15, 2020
                                                            File No. 333-236481

       Dear Mr. Moscato:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our March
3, 2020 letter.

       Amendment No. 1 to Registration Statement on Form S-1

       Recent Developments, page 4

   1.                                                   We refer to prior
comment 1 and reissue in part. Please revise to identify and discuss the
                                                        assets held by your
NGIO subsidiary. In this regard, we note that the January 31, 2020
                                                        balance sheet filed
with NuGenerex's Form 10 registration statement indicates that the
                                                        only assets consisted
of $174 in cash.
   2.                                                   We note your disclosure
on page 96 indicating that pursuant to a May 2020 ruling
                                                        Generex may not issue,
transfer or otherwise dispose of any shares of stock without
                                                        receiving court
approval from the judge in the Utah Third District Court. Please revise to
                                                        highlight this
disclosure in your Summary.
 Joseph Moscato
Generex Biotechnology Corporation
July 7, 2020
Page 2
Corporate Development Concerning COVID-19, page 6

3.     Please revise to clarify the basis for your statement that you have
developed a proprietary,
       patented Ii-Key immune system activation technology that holds promise
for the rapid
       development of a complete SARS-COV-2 Ii-Key peptide vaccine to address
the
       current COVID-19 pandemic. Alternatively, please revise to remove this
and other
       similar statements from the registration statement. As applicable, also
revise this section
       to clarify, if true, that you have not conducted any clinical or
pre-clinical testing to date.
Steps taken..., page 49

4.     Please revise the disclosure on page 52 to explain your basis for the
statement that
       "funding for the development of a vaccine of SARS-CoV-2 virus is in
advanced
       discussions and currently expected that the development costs will be
borne by the U.S.
       and foreign government agencies."
General

5.     We note your response to our prior comment 2 and reissue in part. Please
revise the
       prospectus to address corporate developments concerning the development
of a rapid test
       for 2019-nCOV by NuGenerex Diagnostics or explain why this information
is not
       material to investors.
6.     As you know, the staff is reviewing your Annual Report on Form 10-K for
the fiscal year
       ended July 31, 2019 and have issued comments in connection with that
review. Please
       note that we will not be in a position to declare this registration
statement effective until
       you have resolved all comments raised on the Form 10-K.

       Please contact Ada D. Sarmento at 202-551-3798 or Joe McCann at
202-551-6262 with
any questions.



                                                              Sincerely,
FirstName LastNameJoseph Moscato
                                                              Division of
Corporation Finance
Comapany NameGenerex Biotechnology Corporation
                                                              Office of Life
Sciences
July 7, 2020 Page 2
cc:       Marc J. Ross, Esq.
FirstName LastName