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 9, 2020

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

      Re:   CEL-SCI Corporation
            Post-Effective Amendment No. 2 to Form S-1
            File No. 333-229295

     This office represents CEL-SCI Corporation (the "Company").  Post-Effective
Amendment No. 2 to the Company's Registration Statement on Form S-1 (333-229295)
has been filed with the Commission. The following are the Company's responses to
the comments received by the staff by letter dated March 4, 2020.

     The  numbers  below  correspond  to the  paragraph  numbers in the  staff's
comment letter.


                                                                                    

                                                                                    Page No.

     1.   Revisions  have been made to the  section of the  prospectus  entitled
          "Description of Common Stock" to address this comment.                        5

     2.   The following has been added 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          February 2020  rescinded the exercise of these  warrants,  the Company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.                              2

     3.The shares  issuable upon the exercise of the Series Y warrants have been
          removed from the registration statement.                                      6


     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