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                          April 5, 2024

       Michael Brigham
       Chief Executive Officer
       ImmuCell Corporation
       56 Evergreen Drive
       Portland, ME 04103

                                                        Re: ImmuCell
Corporation
                                                            Registration
Statement on Form S-3
                                                            Filed April 1, 2024
                                                            File No. 333-278438

       Dear Michael Brigham:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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 Tyler
Howes at 202-551-3370 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              Norwood P. Beveridge,
Esq.