[CELL GENESYS, INC. LETTERHEAD]

                               February 14, 2005



VIA FACSIMILE AND EDGAR

United States Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention:  Ms. Anne Nguyen

     RE:  CELL GENESYS, INC. - POST-EFFECTIVE AMENDMENT NO. 1 TO REGISTRATION
          STATEMENT ON FORM S-3 (COMMISSION FILE NO. 333-121732); ACCELERATION
          REQUEST

Dear Ms. Nguyen:

     Pursuant to Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, as amended, Cell Genesys, Inc. (the "Company") hereby
requests that the effective date of the above-referenced Registration Statement
on Form S-3 (as amended, the "Registration Statement") be accelerated so that
the Registration Statement may become effective at 4:00 p.m., Eastern Time, on
February 16, 2005, or at such later time as the Company may request by telephone
to the Commission. The Company hereby authorizes each of Herbert Fockler and
Jeffrey Eisenberg of Wilson Sonsini Goodrich & Rosati, P.C., counsel for the
Company, to make such request on our behalf.

     In connection with the acceleration request, the Company hereby
acknowledges that:

          o    should the commission or the staff, acting pursuant to delegated
               authority, declare the Registration Statement 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 Registration Statement
               effective, does not relieve the Company from its full
               responsibility for the adequacy and accuracy of the disclosure in
               the Registration Statement; and

February 14, 2005
Page 2

          o    the Company may not assert this action as a defense in any
               proceeding initiated by the Commission or any person under the
               federal securities laws of the United States.

     Please direct any questions or comments regarding this request for
acceleration of effectiveness to Herbert Fockler and Jeffrey Eisenberg of Wilson
Sonsini Goodrich & Rosati, P.C. via facsimile at (650) 493-6811 or by telephone
at (650) 493-9300.

                                          Very truly yours,

                                          CELL GENESYS, INC.

                                          /s/ Matthew J. Pfeffer

                                          Matthew J. Pfeffer
                                          Chief Financial Officer

cc:   Wilson Sonsini Goodrich & Rosati