August 4, 2025

Kimberly Graper
Interim Chief Financial Officer
Imunon, Inc.
997 Lenox Drive, Suite 100
Lawrenceville, NJ 08648

        Re: Imunon, Inc.
            Form 10-K for Fiscal Year Ended December 31, 2024
            Filed February 27, 2025
            File No. 001-15911
Dear Kimberly Graper:

       We have reviewed your filing and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2024
Intellectual Property, page 26

1.     In future filings, please revise your intellectual property disclosure
in relation to the
       Company's material patents as follows:

             Clearly describe on an individual or patent family basis whether
each patent is
           owned or licensed, the expiration year or expected expiration year
of each issued
           and pending patent, and the jurisdiction, including any foreign
jurisdiction, of
           each material, pending or issued patent.
             Additionally, it appears that certain of your issued patents
pertaining to the
           TheraPlas and IMNN-001 technologies will expire on dates ranging
from 2025 to
           2028. Revise your discussion to identify with greater specificity
any material
           patent(s) that will expire in the near term. As appropriate, please
provide
           additional risk factor disclosure discussing the extent to which you
face material
           risk stemming from the expiration of these patents, or otherwise
advise.
 August 4, 2025
Page 2
2.     We refer to your disclosure on page 39 stating that you are party to
license agreements
       with Duke University, under which you have exclusive rights to
commercialize
       medical treatment products and procedures based on Duke   s
thermo-sensitive
       liposome technology. Please revise future filings in an appropriate
place to include a
       discussion of the material terms of these or any other material license
agreements,
       including, as applicable:
           Nature and scope of intellectual property transferred;
           Each parties    rights and obligations;
           Duration of agreement and royalty term;
           Termination provisions; and
           Payment provisions, including quantification of any upfront fee and
any
           installments thereof, amounts paid to date, aggregate potential
milestone
           payments segregated by development and commercial milestone
payments, and
           the applicable royalty rates to be paid by each party. In the event
a range is
           provided in place of the actual royalty rate, such range should be
within ten
           percentage points.

       Additionally, in future filings, please file the referenced license
agreements with Duke
       University as exhibits, or otherwise provide us with your analysis as to
why you
       believe they are not required to be filed. Refer to Item 601(b)(10) of
Regulation S-K.

        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.

        Please contact Lauren Sprague Hamill at 303-844-1008 or Jason Drory at
202-551-
8342 if you have questions regarding comments and with any other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Life
Sciences
cc:   Jeffrey Church