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CORRESP
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    SILVERMAN
      SCLAR SHIN & BYRNE PLLC

    Attorney
      at Law

    381
      Park Avenue South, Suite 1601

    New
      York, New York 10016

    Tel.
      No. 212-779-8600

    Telecopy
      Number - (212) 779-8858

                    July
      26,
      2006

    Jeffrey
      Riedler

    Assistant
      Director

    Division
      of Corporation Finance

    Securities
      and Exchange Commission

    100
      F
      Street, NE

    Washington,
      DC 20549

              Re:

              Hemispherx
                Biopharma, Inc.

              Schedule
                14A, amendment No. 1

              Filed
                July 21, 2006

              File
                No. 1-13441

    Dear
      Mr.
      Riedler:

    On
      behalf
      of Hemispherx Biopharma, Inc. (the "Company"), we hereby respond to the comments
      contained in your July 24, 2006 comment letter.

    Proposal
      No. 3: Approval of the Proposal to Amend Our Certificate of Incorporation to
      Increase the Number of Authorized Shares of Common Stock

    Comment
      1. Based
      on
      the third paragraph of this section, it appears you currently have sufficient
      authorized shares for your outstanding options, warrants, convertible
      debentures, and your agreement with Fusion Capital. Do you have any plans to
      issue any of the 100,000,000 shares for which you are seeking shareholder
      approval? For example, we note that you “most likely will (i) attempt to raise
      capital through the sale of [your] common stock or securities convertible into
      or exercisable for common stock; and/or (ii) acquire additional assets.” We also
      note from the second paragraph in the discussion of proposal 4 that you may
      issue some of these shares to Fusion Capital. Please describe in your discussion
      of proposal 3 any plans you currently have to issue any of the shares that
      would
      be authorized through this proposal. After discussing all such plans, state
      that
      you have no other plans besides the plans that are discussed in your
      filing.

          Jeffrey
            Riedler

          July
            26,
            2006

          Page -
            2

    Response:
      The
      Company has no current plans to issue any of the 100,000,000 shares for which
      it
      is seeking stockholder approval. It is conceivable that some of these shares
      might be issued to Fusion Capital in the transaction described in Proposal
      no.
      4. The Company will add the following language to the definitive Schedule14A
      at
      the end of the paragraph 5 in Proposal No. 3 when it is filed:

    “It
      is
      possible that some of these shares could be issued pursuant to the Stock
      Purchase Agreement with Fusion Capital (see Proposal No. 4 below). We do not
      know the actual number of these shares that could be issued to Fusion Capital,
      if any, because the number of shares to be issued is based upon the future
      market price of our Common Stock and we have the ability to limit the number
      of
      shares purchasable under the agreement. In addition, the Stock Purchase
      Agreement, as amended, provides that we may not issue to Fusion Capital more
      than 27,386,723 shares, representing 12,386,723 shares already issued or
      reserved for issuance under the Purchase Agreement, plus 15,000,000 additional
      shares from shares authorized but not reserved for issuance and newly authorized
      shares should Proposal No. 3 be approved. Aside from possible issuances to
      Fusion Capital as discussed above, we have no current plans to issue any of
      the
      shares that would be authorized should this Proposal No. 3 be approved by our
      stockholders.”

    Proposal
      No. 4: Approval of the Issuance of Common Stock to Comply with AMEX Company
      Guide Section 713

    Comment
      2.
      Please
      state whether there is a possibility that Fusion Capital could obtain control
      of
      your company. For example, does your agreement with Fusion Capital include
      limitations on Fusion Capital’s share ownership?

    Response:
      The
      Stock Purchase Agreement (the “Purchase Agreement”) contains a provision that
      limits Fusion Capital’s ownership of Company common stock to no more than 9.9%
      of the outstanding shares of common stock. Accordingly, it is not possible
      that
      Fusion Capital could obtain control of the Company. The Company will add the
      following language to the definitive Schedule14A in the middle of the second
      paragraph of the disclosure in Proposal No. 4 when it is filed:

    “In
      addition, Fusion Capital cannot purchase common stock under the Purchase
      Agreement to the extent that, following such purchase and after giving effect
      to
      such purchase, it, together with its affiliates, would beneficially own in
      excess of 9.9% of the outstanding shares of our common stock.”

    Comment
      3. Please
      discuss the anticipated uses of the proceeds from the issuance to Fusion
      Capital, as required by Item 11(c)(2) of Schedule 14A. Also discuss any other
      reasons for the issuance, as required by Item 11(d).

        Jeffrey
          Riedler

        July
          26,
          2006

        Page
          -
          3

    Response:
      The
      Company cannot determine the amount of proceeds that it will receive under
      the
      Purchase Agreement and, accordingly, cannot predict the amount of proceeds
      to be
      allocated to anticipated use of proceeds. The Company will add the following
      paragraph to the definitive Schedule14A after the second paragraph of the
      disclosure in Proposal No. 4 when it is filed:

    “We
      anticipate applying the proceeds we receive from the Purchase Agreement to
      extend our New Brunswick facility for the production of Ampligen® and Alferon N
      Injection®, Research and Development and for general corporate
      purposes.”

    The
      Company does not have any additional reasons for issuance of the shares pursuant
      to the Purchase Agreement other than to raise funds for the purposes described
      in response to comment no. 3.

    The
      Company acknowledges that: (i) it is responsible for the adequacy and accuracy
      of the disclosure in the filing; (ii) 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 (iii) 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/Richard
                Feiner

              Richard
                Feiner