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SEC Company Response from SOLIGENIX, INC. (SNGX) (CIK 0000812796) (SNGX) — Apr 13, 2016

SOLIGENIX, INC. (SNGX) (CIK 0000812796)
Date: April 13, 2016 · CIK: 0000812796 · Accession: 0001213900-16-012466

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File numbers found in text: 333-192908

Referenced dates: April 13, 2016

Date
April 13, 2016
Author
Duane Morris LLP
Form
CORRESP
Company
SOLIGENIX, INC. (SNGX) (CIK 0000812796)

Letter

VIA EDGAR AND FEDEX Office of Healthcare and Insurance Securities and Exchange Commission Re Soligenix, Inc. Post-Effective Amendment No. 3 to Form S-1 Filed March 31, 2016 File No. 333-192908

Dear Ms. Hayes:

On behalf of our client, Soligenix, Inc. (the “Company”), we are responding to the comment of the staff (the “Staff”) of the Securities and Exchange Commission contained in its letter dated April 13, 2016 (the “Letter”) relating to the captioned Post-Effective Amendment No. 3 to Form S-1 (“Registration Statement”).

Set forth below is our response to the Staff’s comment. For your convenience we have incorporated the Staff’s comment into this response letter.

General

1. The financial statements and related disclosure in this filing have not been updated to reflect the results for the year ended December 31, 2015 as required by Item 8-08 of Regulation S-X. Please amend this filing to include the required financial statements and related information.

Duane Morris llp

SOUTH BISCAYNE BOULEVARD, SUITE 3400 MIAMI, FL 33131-2318 PHONE: +1 305 960 2200 FAX: +1 305 960 2201

Page 2

Response:

In response to the Staff’s comment, the Company has amended the Registration Statement to include the required financial statements and related information

When the Company requests acceleration of the effective date of the Registration Statement, as amended, the Company will provide a written statement acknowledging the matters noted in the three bullet points included in the Letter.

Please contact me at (561) 962-2139 with any questions or further comments regarding our response to the Staff’s comments.

Sincerely,
Duane Morris LLP

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CORRESP
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filename1.htm

    NEW
    YORK

    LONDON

    SINGAPORE

    PHILADELPHIA

    CHICAGO

    WASHINGTON, DC

    SAN FRANCISCO

    SILICON VALLEY

    SAN DIEGO

    SHANGHAI

    BOSTON

    HOUSTON

    LOS ANGELES

    HANOI

    HO CHI MINH CITY

        FIRM
        and AFFILIATE OFFICES

        driscoll
        r. ugarte, P.A.

E-MAIL: drugarte@duanemorris.com

        www.duanemorris.com

    ATLANTA

    BALTIMORE

    WILMINGTON

    MIAMI

    BOCA RATON

    PITTSBURGH

    NEWARK

    LAS VEGAS

    CHERRY HILL

    LAKE TAHOE

    MYANMAR

    OMAN A GCC REPRESENTATIVE OFFICE

    OF DUANE MORRIS

    MEXICO CITY

    ALLIANCE WITH

    MIRANDA & ESTAVILLO SRI LANKA

    ALLIANCE WITH

    GOWERS INTERNATIONAL

April 13, 2016

VIA EDGAR AND FEDEX

Suzanne Hayes

Assistant Director

Office of Healthcare and Insurance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re Soligenix, Inc.

Post-Effective Amendment No. 3 to Form S-1

Filed March 31, 2016

  File No. 333-192908

Dear Ms. Hayes:

On behalf of our
client, Soligenix, Inc. (the “Company”), we are responding to the comment of the staff (the “Staff”) of
the Securities and Exchange Commission contained in its letter dated April 13, 2016 (the “Letter”) relating to the
captioned Post-Effective Amendment No. 3 to Form S-1 (“Registration Statement”).

Set forth below
is our response to the Staff’s comment. For your convenience we have incorporated the Staff’s comment into this response
letter.

General

 1. The financial statements and related disclosure in this filing have not been updated to reflect
the results for the year ended December 31, 2015 as required by Item 8-08 of Regulation S-X. Please amend this filing to include
the required financial statements and related information.

    Duane
    Morris llp

    200
    SOUTH BISCAYNE BOULEVARD, SUITE 3400    MIAMI, FL 33131-2318	PHONE: +1 305 960 2200    FAX:
    +1 305 960 2201

Page 2

Response:

In response to the Staff’s comment, the Company
has amended the Registration Statement to include the required financial statements and related information

When the Company
requests acceleration of the effective date of the Registration Statement, as amended, the Company will provide a written statement
acknowledging the matters noted in the three bullet points included in the Letter.

Please contact me
at (561) 962-2139 with any questions or further comments regarding our response to the Staff’s comments.

    Sincerely,

    Duane Morris LLP

    /s/ Driscoll R. Ugarte

    Driscoll
R. Ugarte

cc:  Mr. Scot Foley, Division of Corporation Finance

    Christopher J. Schaber,
Ph.D., Chief Executive Officer and President