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SEC Company Response from CEL SCI CORP (CVM) (CIK 0000725363) (CVM) — Apr 30, 2007

CEL SCI CORP (CVM) (CIK 0000725363)
Date: April 30, 2007 · CIK: 0000725363 · Accession: 0001004878-07-000063

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File numbers found in text: 001-11889

Referenced dates: March 28, 2007

Date
April 25, 2007
Author
Geert R. Kersten, Chief Executive Officer
Form
CORRESP
Company
CEL SCI CORP (CVM) (CIK 0000725363)

Letter

Re: CEL-SCI Corporation Form 10-K File No. 001-11889

CEL-SCI CORPORATION

8229 Boone Blvd. #802 Vienna, VA 22182 (703) 506-9460

April 25, 2007

Dana Hartz Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, DC 20549

The following is the response of CEL-SCI Corporation (the "Company") to your letter dated March 28, 2007.

Geert R. Kersten, the Company's Chief Executive and Financial Officer, evaluated the effectiveness of the Company's disclosure controls and procedures (as defined in Rule 13a-15(e) of the Securities Exchange Act of 1934) as of the end of the period covered by the Company's report on From 10-K for the year ended September 30, 2006, and in his opinion the Company's disclosure controls and procedures are effective. There were no changes in the Company's internal controls over financial reporting that occurred during the fiscal year ended September 30, 2006 that have materially affected, or are reasonably likely to materially affect, the Company's internal control over financial reporting.

The Company understands that:

o The Company is responsible for the adequacy and accuracy of the disclosure in its 10-K report;

o Staff comments, or changes to the disclosure in response to staff comments, do not foreclose the Commission from taking any action with respect to the 10-K report; and

o 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.

Very Truly Yours,
/s/ Geert R. Kersten
--------------------------------------
Geert R. Kersten, Chief Executive Officer

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
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<TEXT>

                               CEL-SCI CORPORATION

                              8229 Boone Blvd. #802
                                Vienna, VA 22182
                                 (703) 506-9460

                                 April 25, 2007

Dana Hartz
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549

      Re:   CEL-SCI Corporation
            Form 10-K
            File No. 001-11889

      The following is the response of CEL-SCI Corporation (the "Company") to
your letter dated March 28, 2007.

      Geert R. Kersten, the Company's Chief Executive and Financial Officer,
evaluated the effectiveness of the Company's disclosure controls and procedures
(as defined in Rule 13a-15(e) of the Securities Exchange Act of 1934) as of the
end of the period covered by the Company's report on From 10-K for the year
ended September 30, 2006, and in his opinion the Company's disclosure controls
and procedures are effective. There were no changes in the Company's internal
controls over financial reporting that occurred during the fiscal year ended
September 30, 2006 that have materially affected, or are reasonably likely to
materially affect, the Company's internal control over financial reporting.

      The Company understands that:

          o    The Company is  responsible  for the adequacy and accuracy of the
               disclosure in its 10-K report;

          o    Staff comments, or changes to the disclosure in response to staff
               comments,  do not foreclose the Commission from taking any action
               with respect to the 10-K report; and

          o    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.

                                Very Truly Yours,

                                /s/ Geert R. Kersten
                                    --------------------------------------
                                    Geert R. Kersten, Chief Executive Officer

</TEXT>
</DOCUMENT>