HART & HART, LLC
                                ATTORNEYS AT LAW
                             1624 Washington Street
                                Denver, CO 80203

William T. Hart, P.C.              ________                   harttrinen@aol.com
Will Hart                                                    Fax: (303) 839-5414
                                 (303) 839-0061
Fax: (303) 839-5414

                                February 27, 2013

Johnny Gharib
Securities and Exchange Commission
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. 2
to the Company's Preliminary Proxy Statement has been filed with the Commission.
The  section of the Proxy  Statement  pertaining  to the  Amended  and  Restated
Articles of  Incorporation  has been modified in response to the staff's  letter
dated February 25, 2013.

     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