CORRESP 1 filename1.txt CEL-SCI CORPORATION 8229 Boone Blvd. #802 Vienna, VA 22182 (703) 506-9460 July 8, 2020 Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: CEL-SCI Corporation Form S-1 SEC File No. 333-239674 CEL-SCI Corporation (the "Company") requests that the effective date of the above captioned Registration Statement be accelerated to Friday, July 10, 2020, 2:30 P.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, CEL-SCI CORPORATION /s/ Patricia B. Prichep Patricia B. Prichep Senior Vice President of Operations