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                    May 5, 2020

       Joseph Moscato
       Chief Executive Officer
       NuGenerex Immuno-Oncology, Inc.
       10102 USA Today Way
       Miramar, FL 33025

                                                        Re: NuGenerex
Immuno-Oncology, Inc.
                                                            Registration
Statement on Form 10-12G
                                                            Filed March 12,
2020
                                                            File No. 000-56153

       Dear Mr. Moscato:

               We issued comments to you on the above captioned filing on April
8, 2020. As of the
       date of this letter, these comments remain outstanding and unresolved.
We expect you to
       provide a complete, substantive response to these comments by May 19,
2020.

               If you do not respond, we will, consistent with our obligations
under the federal securities
       laws, decide how we will seek to resolve material outstanding comments
and complete our
       review of your filing and your disclosure. Among other things, we may
decide to release
       publicly, through the agency's EDGAR system, all correspondence,
including this letter, relating
       to the review of your filings, consistent with the staff's decision to
publicly release comment and
       response letters relating to disclosure filings it has reviewed.

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




                    Sincerely,


                    Division of Corporation Finance

                    Office of Life Sciences
       cc:                                              Jeffrey Wofford, Esq.