October 25, 2019

Garo H. Armen, Ph.D.
Chief Executive Officer
Agenus Inc.
3 Forbes Road
Lexington, Massachusetts 02421

       Re: Agenus Inc.
           Form 10-K for Fiscal Year Ended December 31, 2018
           Response dated October 7, 2019
           File No. 000-29089

Dear Dr. Armen:

       We have reviewed your October 7, 2019 response to our comment letter and
have the
following comments. In some of our comments, we may ask you to provide us with
information
so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

      After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
September 19, 2019 letter.

Form 10-K for Fiscal Year Ended December 31, 2018

Item 1. Business
Our Business, page 3

1.    We note your response to our prior comment 2. However, terms such as
"best-in-class"
      and "first-in-class" suggest that the product candidates are effective
and likely to be
      approved. In future filings, please delete these references. If your use
of these terms was
      intended to convey your belief that the products are based on a novel
technology or
      approach and/or is further along in the development process than a third
party, you may
      discuss how your technology differs from existing antibodies and, if
applicable, that you
      are not aware of competing products that are further along in the
development process.
      Statements such as these should be accompanied by cautionary language
that the
 Garo H. Armen, Ph.D.
Agenus Inc.
October 25, 2019
Page 2
      statements are not intended to give any indication that the product
candidates have been
      proven effective or that they will receive regulatory approval.
Item 1A. Risk Factors
Risks Related to our Tokens, page 36

2.    We note your responses to our prior comments 4-10 that you are not
pursuing the offering
      of Tokens and will remove from future filings information regarding the
Token offering.
      Please confirm that you will disclose in future filings, to the extent
true, that you are not
      pursuing the offering of Tokens and have not issued any Tokens.
       You may contact Lisa Vanjoske at 202-551-3614 or Mary Mast at
202-551-3613 if
you have questions regarding comments on the financial statements and related
matters.
Please contact Irene Paik at 202-551-6553 or Mary Beth Breslin at 202-551-3625
with any
other questions.



                                                             Sincerely,
FirstName LastNameGaro H. Armen, Ph.D.
                                                             Division of
Corporation Finance
Comapany NameAgenus Inc.
                                                             Office of Life
Sciences
October 25, 2019 Page 2
cc:       Zachary R. Blume - Ropes & Gray LLP
FirstName LastName