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                                June 29, 2020

       Cameron Durrant, M.D.
       Chief Executive Officer
       Humanigen, Inc.
       533 Airport Boulevard, Suite 400
       Burlingame, California 94010

                                                        Re: Humanigen, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed June 15, 2020
                                                            File No. 333-239161

       Dear Dr. Durrant:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-1

       Overview, page 1

   1.                                                   We note your disclosure
that lenzilumab has been shown to be generally safe in Phase I
                                                        and Phase II studies.
Please remove all statements in your prospectus that present your
                                                        conclusions regarding
the safety or efficacy of your product candidates as these
                                                        determinations are
within the authority of the FDA and comparable regulatory bodies.
       COVID-19, page 1

   2.                                                   In the last paragraph
of this section, please briefly indicate, if true, that the compassionate
                                                        use study of lenzilumab
in the Mayo Clinic system did not contain a control group.
 Cameron Durrant, M.D.
FirstName
Humanigen,LastNameCameron  Durrant, M.D.
            Inc.
Comapany
June       NameHumanigen, Inc.
     29, 2020
June 29,
Page 2 2020 Page 2
FirstName LastName
Our Pipeline, page 2

3.       Please revise your table in this section and on page 35 to add
separate columns for each
         phase of clinical development     Preclinical, Phase 1, Phase 2 and
Phase 3     and include an
         arrow for each of your product candidates showing the current status
of development for
         each such product candidate for the indications in your table.
General

4.       According to media reports, lawsuits have been filed in the State of
New York with
         respect to your June 2, 2020 private placement. Please tell us whether
such lawsuits
         present material risks to you, and, if so, revise the prospectus to
discuss them.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Tim Buchmiller at (202) 551-3635 or Joseph McCann at
(202) 551-6262
with any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Life
Sciences
cc:      Kevin L. Vold, Esq.