July 15, 2025

Geert Kersten
Chief Executive Officer
CEL-SCI Corporation
8229 Boone Blvd. #802
Vienna, Virginia 22182

       Re: CEL-SCI Corporation
           Registration Statement on Form S-3
           Filed July 3, 2025
           File No. 333-288515
Dear Geert Kersten:

       We have conducted a limited review of your registration statement and
have the
following comments.

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form S-3
Cover Page

1.     Please revise the header on the cover page of the prospectus to specify
the total
       amount ($100,000,000) and the types of securities being registered.
Signatures, page 28

2.     Please revise the signature section to indicate which officer is signing
in the capacities
       of principal executive officer, principal financial officer, and
controller or principal
       accounting officer.
 July 15, 2025
Page 2
Exhibits

3.     Please file a legal opinion as Exhibit 5.1 with the next amendment to
your registration
       statement.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Chris Edwards at 202-551-6761 or Tim Buchmiller at
202-551-3635
with any other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Life
Sciences
cc:   William T. Hart, Esq.