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Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                   March 28, 2007   Mr. Geert Kersten Chief Financial Officer CEL-SCI Corporation 8229 Boone Blvd., Suite 802 Vienna, VA 22182
Re: CEL-SCI Corporation
Form 10-K for the Fiscal Year Ended September 30, 2006 Filed December 21, 2006
 File No. 001-11889

Dear Mr. Kersten:

We have reviewed your filing and have the following comment.  We have limited
our review to only your financia l statements and related disclosures and do not intend to
expand our review to other portions of your documents.  In our comment, we ask you to
provide us with information so we may bette r understand your disclosure.  Please be as
detailed as necessary in your explanation.  Af ter reviewing this information, we may raise
additional comments.     Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our  comment or any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the Fiscal Year Ended September 30, 2006

Item 9A. Disclosure Controls and Procedures

1. You do not clearly conclude whether or  not your disclosure controls and
procedures are effective.  Please provid e us clarification in a disclosure-type
format.

Mr. Geert Kersten
CEL-SCI Corporation March 28, 2007 Page 2
 As appropriate, please respond to this comm ent within 10 business days or tell us
when you will provide us with a response.  Please furnish a letter that keys your response to our comment and provide the requested information.  Detailed  letters greatly facilitate
our review.  Please furnish the letter to  us via EDGAR under the form type label
CORRESP.

 We urge all persons who are responsible  for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comment, please provide , in your letter, a
statement from the company acknowledging that:  ‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
‚ the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comment on your filings.
 You may contact Dana Hartz,  Staff Accountant, at ( 202) 551-3648 or Mary Mast,
Review Accountant, at (202) 551-3613 if you ha ve questions regardi ng the comment.  In
this regard, please do not hesitate  to contact me at (202) 551-3679.
  Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant