March 12, 2020

Geert Kersten
Chief Executive Officer
CEL-SCI Corporation
8229 Boone Blvd., Suite 802
Vienna, Virginia 22182

       Re: CEL-SCI Corporation
           Post-Effective Amendment No. 2 to Registration Statement on Form S-1
           Filed March 6, 2020
           File No. 333-229295

Dear Mr. Kersten:

      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 4,
2020 letter.

Post-Effective Amendment No. 2 to Registration Statement on Form S-1 filed
March 6, 2020

Description of Common Stock, page 5

1.     We note your revisions in response to our prior comment 1. Please revise
the last
       sentence in this section to clarify that there is uncertainty as to
whether any court, not only
       the U.S. District Court for the District of Delaware, would enforce your
exclusive forum
       provision. In addition, as requested previously, please include risk
factor disclosure
       regarding this provision to update the risk factor disclosure provided
in your annual report
       on Form 10-K that is incorporated by reference. Finally, please file
your amended bylaws
       as an exhibit to this registration statement.
 Geert Kersten
CEL-SCI Corporation
March 12, 2020
Page 2
General

2.    We note your revisions in response to our prior comment 3. However, you
continue to
      state throughout the prospectus that the warrants were issued at various
dates between
      February 2016 and July 2018 even though the Form S-1 that was declared
effective on
      February 13, 2019 indicates that the warrants were issued at various
dates between
      February 2017 and July 2018. Please revise your prospectus to reconcile
this discrepancy
      or advise.
       Please contact Irene Paik at 202-551-6553 or Celeste Murphy at
202-551-3257 with any
questions.



                                                          Sincerely,
FirstName LastNameGeert Kersten
                                                          Division of
Corporation Finance
Comapany NameCEL-SCI Corporation
                                                          Office of Life
Sciences
March 12, 2020 Page 2
cc:       William T. Hart, Esq.
FirstName LastName