CEL-SCI CORPORATION
                             8229 Boone Blvd., #802
                                Vienna, VA 22182
                                 (703) 506-9460


                                  July 5, 2018


Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549

      Re:   CEL-SCI Corporation
            Form S-1
            SEC File No. 333-225843


      CEL-SCI Corporation (the "Company") requests that the effective date of
the above captioned Registration Statement be accelerated to July 9, 2018, at
11:00 a.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  this  action  as  defense  in any
               proceedings  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








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