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


                                February 21, 2020


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

      Re:   Post-Effective Amendment No. 1 to Registration Statement on Form
S-1
            File No. 333-229295


     CEL-SCI  Corporation  (the  "Company")  requests  that the  above-captioned
Post-Effective   Amendment  No.  1  to  registration   statement  333-229295  be
withdrawn.  The reason for this request is that the Post-Effective Amendment was
filed on the edgar  system  under the code S-1/A when it should  have been filed
under the code POS AM.

     No securities were sold by means of the  Post-Effective  Amendment No. 1 to
the registration statement.

                                     Very Truly Yours,

                                     CEL-SCI CORPORATION


                                     /s/ Geert R. Kersten
                                     Geert R. Kersten
                                     Chief Executive Officer












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