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


                                  July 21, 2015

Johnny Gharib
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

      Re:   CEL-SCI Corporation

     This office  represents  CEL-SCI  Corporation (the  "Company").  The second
amendment to the Company's 10-K report for the year ended September 30, 2014 has
been  filed with the  Commission.  This  letter is in  response  to the  comment
received from the staff on May 6, 2015.

     The Company's various Incentive Stock Option,  Non-Qualified  Stock Option,
Stock Bonus and Stock  Compensation Plans are the same, except for the number of
shares authorized for issuance under the plans,  which in some cases varies from
year to year.  However,  insofar as Item 601(4) of  Regulation  S-K is concerned
(Instruments  defining the rights of security holders,) the respective plans are
identical to each other,  i.e.,  each  Incentive  Stock Option Plan has the same
terms and  provisions as the other  Incentive  Stock Option plans.  As a result,
only the most recent plans filed as exhibits to S-8 registration statements have
been incorporated by reference.

     Exhibit 4 (f) - the 2014  Incentive  Stock  Bonus Plan has been filed as an
exhibit to Amendment No. 2 to the Company's 10-K report.

     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