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


                                  July 8, 2008



Sebastian Gomez Abero
Securities and Exchange Commission
Mail Stop 6010
100 F Street, NE
Washington, DC 20549

      Re:   CEL-SCI Corporation
            Form S-3
            File No. 333-151667


      CEL-SCI Corporation (the "Company") requests that the effective date of
the above captioned Registration Statement be accelerated to July 10, 2008,
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  staff  comments  and the  declaration  of
          effectiveness  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 Prichep

                                           Patricia Prichep
                                           Senior Vice President of Operations