CEL-SCI CORPORATION

                              8229 Boone Blvd. #802
                                Vienna, VA 22182
                                 (703) 506-9460


                                 August 1, 2007


John Krug
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549

      Re:   CEL-SCI Corporation
            Form S-3
            File No. 333-144522

      CEL-SCI Corporation (the "Company") requests that the effective date of
the above captioned Registration Statement be accelerated to Friday, August 3,
2007, 11:00 a.m. Eastern time, or as soon as practicable thereafter.

      The Company understands that:

     o    should the  Commission  or the staff,  acting  pursuant  to  delegated
          authority,  declare the filing  effective,  it does not  foreclose the
          Commission from taking any action with respect to the filing;

     o    the  action  of  the  Commission  or the  staff,  acting  pursuant  to
          delegated  authority,  in  declaring  the filing  effective,  does not
          relieve the Company from its full  responsibility for the adequacy and
          accuracy of the disclosure in the filing; and

     o    the Company  may not assert this action as defense in any  proceedings
          initiated by the Commission or any person under the federal securities
          laws of the United States.

                                Very Truly Yours,


                                /s/ Patricia Prichep
                                -------------------------------
                                Patricia Prichep, Senior Vice President
                                of Operations