Advaxis, Inc.

9 Deer Park Drive, Suite K-1

Monmouth Junction, NJ 08852

October 20, 2021

U.S. Securities and Exchange Commission

Division of Corporate Finance

Office of Life Sciences

100 F Street NE

Washington, DC 20549

Attention: David Gessert

VIA EDGAR

Re:	Advaxis, Inc.
	Registration Statement on Form S-4
	Filed August 25, 2021
	File No. 333-259065

Dear Mr. Gessert:

In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of Amendment No. 2 to the Registration Statement on Form S-4 (File No. 333-259065) (the “Registration Statement”) of Advaxis, Inc. We respectfully request that the Registration Statement become effective as of 4:00 p.m., Eastern time, on October 20, 2021, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Morgan, Lewis & Bockius LLP, by calling Justin W. Chairman at (215) 963-5061 or Emily Drazan Chapman at (202) 739-5699.

Very Truly Yours,
Advaxis, Inc.
By:	/s/ Kenneth A. Berlin
Name:	Kenneth A. Berlin
Title:	President and Chief Executive Officer

cc: Morgan, Lewis & Bockius LLP