HART & HART, LLC
                                ATTORNEYS AT LAW
                             1624 Washington Street
                                Denver, CO 80203
William T. Hart, P.C.              ________
Will Hart                                              acsimile:  (303) 839-5414
                                 (303) 839-0061

                                February 7, 2013

Amy Reischauer
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

      Re:   CEL-SCI Corporation
            Registration Statement on Form S-3
            File No. 333-186103

     This office represents CEL-SCI Corporation (the "Company"). Amendment No. 1
to the  Company's  registration  statement  on Form S-3 has been  filed with the
Commission.  This  letter  provides  the  Company's  responses  to the  comments
received from the staff by letter dated January 30, 2013. The paragraph  numbers
in this letter  correspond  with the numbered  paragraphs in the staff's comment
letter.  The number under the "page number" column  indicates the page number in
the Registration Statement where the response to the comment can be found.

                                                                     Page Number

1.      The registration statement has been revised such that
        notes or other forms of debt are not being registered.      2, 3, 12, 27

2.      Comment complied with.                                         Exhibit 5

3.      Comment complied with.                                         Exhibit 5

4.      Comment complied with.                                         Exhibit 5


If you  should  have any  questions  concerning  the  foregoing,  please  do not
hesitate to contact the undersigned.

                                Very Truly Yours,

                                HART & HART, LLC

                               /s/ William T. Hart
                               By
                                  William T.  Hart