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


                                 April 20, 2015

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

      Re:   CEL-SCI Corporation
            Form 10-K for Fiscal Year Ended September 30, 2014
            Filed December 23, 2014
            File No. 001-11889


     This office  represents  CEL-SCI  Corporation (the "Company").  This letter
provides the  Company's  responses to the  comments  received  from the staff by
letter dated March 27, 2015.  The  paragraph  numbers in this letter  correspond
with the numbered  paragraphs in the staff's comment  letter.  The numbers under
the "Page No." column  refer to the pages in the  Company's  amended 10-K report
where the Company's response to the particular comment can be found.

                                                                        Page No.


     1.   Comment complied with. We believe the Company's  disclosure
          regarding its patents  complies with Item 101(c) (iv) of
          Regulation  S-K and is consistent with that of other issuers
          in the biotech industry.                                       7

     2.   Comment complied with.                                         5

     3.   Comment complied with.                                         6, 23

     4.   Comment complied with.                                         18, 19

     5.   Comment complied with.                                         19

     6.   Comment complied with.                                         20



     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