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


                                January 24, 2008

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

      Re:   CEL-SCI Corporation
            Preliminary Proxy Statement
            File No. 001-11889


     This office represents CEL-SCI Corporation (the "Company"). Amendment No. 1
to the Company's proxy statement has been filed with the Commission.

      In response to the staff's letter dated January 18, 2008, the following
paragraph has been added to the section of the proxy statement pertaining to the
proposed reverse split.

      CEL-SCI's Articles of Incorporation provide that CEL-SCI is authorized to
issue 300,000,000 shares of common stock. The reverse split, if adopted, would
not change the number of shares of common stock which CEL-SCI is authorized to
issue. However, a reverse split would reduce the number of CEL-SCI's outstanding
shares, which would enable CEL-SCI to issue more shares that it would be able to
issue if the reverse split was not adopted. CEL-SCI does not have any plans to
issue any additional shares of its common stock, other than shares which it
would be required to issue in connection with outstanding options or warrants,
or shares which have customarily been issued pursuant to CEL-SCI's stock bonus
or compensation plans.

      The Company understands that:

     o    The  Company is  responsible  for the  adequacy  and  accuracy  of the
          disclosure in the proxy statement;

     o    Staff  comments  or changes to the  disclosure  in  response  to staff
          comments in the filings  reviewed  by the staff do not  foreclose  the
          Commission from taking any action with respect to the proxy statement;
          and

     o    The  Company  may  not  assert  staff  comments  as a  defense  in any
          proceeding initiated by the Commission or any person under the federal
          securities laws of the United States.


                                Very Truly Yours,

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