SecProbe.io

July 2 , 2015

Via E-Mail
Thomas K. Equels
Chief Financial  Officer
Hemispherx Biopharma, Inc.
1617 JFK Boulevard
Philadelphia, Pennsylvania 19103

Re: Hemispherx Biopharma, Inc.
  Registration Statement on Form S-3
Filed June 25 , 2015
  File No. 333-205228

Dear Mr. Equels :

We have limited our review of your registra tion statement to the issue s we have
addressed in the comment s below.

1. We are currently processing your pending request for confidential treatment .  Please be
advised that we will not  be in a position to declare this  registration statement effective
until we re solve all issues concerning the  confidential treatment request.

2. Please note that your registration statement  on Form S-3 must be signed by your chief
financial officer and controller/ principal accounting officer. Any person who occupies
more than one of the specified positions should indicate each capacity in which he or she
signs the report. Please ame nd your registration statement to include  these signatures. See
Instruction 1 to the Signatures section of Form S -3 for guidance.

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 the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and a dequacy of the disclosures they have made.

Notwithstanding our comment , in the event you request acceleration of the effective date
of the pending registration statement , please provide a written statement from the company
acknowledging that:

 should t he Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

Thomas K. Equels
Hemispherx  Biopharma, Inc.
July 2 , 2015
Page 2

 the action of the Commission or the staff, acting pursuant to delega ted authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of  the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the p roposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

You may contact P reston Brewer at  (202) 551 -3969 , Dan Greenspan  at (202) 551 -3623 or
me at (202) 551 -3715 with any questions.

Sincerely,

 /s/ Daniel Greenspan for

 Jeffrey P. Riedler
 Assistant Director

cc: Via E -Mail
Richard Feiner, Esq.
 Silverman Shin Byrne & Gilchrest