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

                                  March 4, 2020

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

         Re:      CEL-SCI Corporation
                  Post-Effective Amendment No. 1 to Form S-1
                  File No. 333-229295

     This office represents CEL-SCI Corporation (the "Company"). With respect to
the staff's  letter dated March 4, 2020,  we propose to add the following to the
section of the prospectus entitled "Recent Developments".

          "In  February  2020 we issued  44,065  shares of our  common
     stock to three  persons upon the  exercise of warrants  which had
     exercise prices between $2.24 and $3.60 per share.  However,  the
     44,065  shares were not  registered  pursuant to Section 5 of the
     Securities  Act of 1933 and no exemption  from  registration  was
     available for the issuance of these  shares.  If the persons that
     exercised  these  warrants  sought to rescind the exercise of the
     warrants  we  would  have  to  pay  these  persons  approximately
     $126,000."

     As noted  above,  if the three  persons  who  exercised  their  warrants in
February  2020  rescinded the exercise of these  warrants,  the Company would be
required  to pay  these  persons  approximately  $126,000.  In  comparison,  the
Company,  aside  from  other  contractual   obligations  (employment  contracts,
remaining  amounts which the Company  estimates will be required to complete its
Phase III  clinical  trial,  etc.),  is required  to make lease  payments on its
manufacturing facility of approximately $150,000 per month.  Accordingly,  we do
not believe that the potential  payment of $126,000 to the persons who exercised
their  warrants in February  2020 is material and  therefore  disclosure of this
potential  payment is not required in the  Company's  annual report on Form 10-K
for the year ended September 30, 2019.

     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