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                                                                                             November 26, 2008

 Mr. Thomas N. Konatich Chief Financial Officer SIGA Technologies, Inc.  420 Lexington Avenue, Suite 408 New York, NY   10170
Re: SIGA Technologies, Inc.
 Form 10-K for the Year Ended December 31, 2007  Filed March 13, 2008
 Form 10-Q for the Quarterly Period Ended September 30, 2008  Filed on November 6, 2008
 Form DEF 14A  Filed on April 9, 2008  File No. 000-23047

Dear Mr. Konatich:

We have reviewed your filings and have the following comments. We have
limited our review of your filings to those issu es we have addressed in our comments. In
our comments, we ask you to provide us with information to better understand your disclosure. Where a comment requests you to  revise disclosure, the information you
provide should show us what the revised disc losure will look like and identify the annual
or quarterly filing, as appli cable, in which you intend to fi rst include it.  If you do not
believe that revised disclosure  is necessary, explain the reason in your response.  After
reviewing the information provided, we may raise additional comments and/or request
that you amend your filings.   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  comments or on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Thomas N. Konatich
SIGA Technologies, Inc.  November 26, 2008 Page 2
 Form 10-K for the Year Ended December 31, 2007

General

 1. We note your reference to grant agreem ents with NIH throughout the Form 10-K
and your statement on page 37 that for the years ended December 31, 2007, 2006, and 2005, revenues from NIH contracts a nd grants were 71%, 53%, and 87%,
respectively, of total reve nues recognized.  We note that you have included one
agreement with NIH from September 2006 as an exhibit to the Form 10-K.  In the text of the Form 10-K, however, you re fer to other contracts with NIH from
October and August of 2006 and July and September of 2007.  Please include all
material contract and grant agreements with  NIH as exhibits to the Form 10-K.  If
the agreements with NIH from Oct ober and August of 2006 and July and
September of 2007 are not material, pleas e provide us with your analysis
supporting this determination.

Form 10-Q for the Quarterly p eriod ended September 30, 2008

Consolidated Financial Statements (Unaudited)

 3.  Stockholders’ Equity, page 8

2. You disclose that you entered into a letter agreement with MacAndrews &
Forbes, LLC (M&F) whereby they committe d to invest up to $8 million over a
one-year period.  You indicate that M&F will receive common stock at the lesser
of $3.06 per share and the volume-weighted average price per share for the five
trading days immediately preceding each funding date as well as warrants.
Although you indicate that M&F will receive common stock and warrants upon
your request for funding, you also indicate th at M&F has the option to invest in
you at the same terms for a one-year peri od.  Please explain to us why you do not
apparently account for the right that M&F holds to purchase your stock as a
liability under EITF 00-19.  In  this regard, it appears th at if your stock price drops
substantially you may not have  enough authorized shares  to issue to M&F if it
exercises its right to inve st in you as discussed in paragraph 19 of SFAS 00-19.
 3. You disclose your intent to charge the transaction costs asso ciated with your
M&F letter agreement to additional pa id-in capital upon the issuance of common
stock and warrants under the agreement.  Please explain to us how you intend to
account for these transaction costs if you do not draw the entire $8 million under
the agreement and revise your disclosures as  appropriate.  Please reference for us
the authoritative literature you reli ed upon to support your accounting.

Mr. Thomas N. Konatich
SIGA Technologies, Inc.  November 26, 2008 Page 3
 7.  Commitments and Contingencies

 Other, page 10

 4. Please revise your disclosure to include an  estimate of the possible loss or range
of loss or state that such an estimate cannot  be made as appropriate.  If you cannot
make an estimate, please disclose the facts and circumstances that prevent management from making such an estimate and include a discussion of what is being sought in the complaint.  Re fer to paragraph 10 of SFAS 5.

Item 2.  Management’s Discussion and Analys is of Financial Condition and Results of
Operations
Results of Operations, page 14
 5. We note that the company has experienced material changes in its accounts
receivable, prepaid expenses and defe rred revenue balances from December 31,
2007 to September 30, 2008.  Please revise  the discussion in your MD&A to
provide an explanation for the material cha nges to these balance sheet items.  Item
303(b)(1) of Regulation S-K requires you to  “Discuss any material changes in
financial condition from the end of the pr eceding fiscal year to the date of the
most recent interim balance sheet provided.”

DEF 14A
6. We note your statement on page 15 that , “In reviewing and recommending the
compensation of the Chief Executive Offi cer and other executive officers, the
Compensation Committee considers the co mpensation awarded to officers of
similarly situated companies.”  Please di sclose if the Committee engaged in any
benchmarking of total compensation, or any material element of compensation,
identifying the benchmark and, if applicab le, its components.  You should identify
the companies that comprise the peer  group used for benchmarking purposes,
provide insight into the basis for sel ecting the peer group, and disclose the
relationship between actual compensation and the data utilized in the benchmarking or peer group studies.  See Item 402(b)(xiv) of Regulation S-K and
our related Compliance & Disc losure Interpretation 118.05.
 7. We note your statement on page 16 that, “The Compensation Committee
evaluates at least once a year the perf ormance of our officers and other key
employees in light of goals and objectiv es established by the Committee . . . .”
Please disclose these performance obj ectives that are tied to each named
executive officer's compensation.  Altern atively, provide a ju stification for the
omission in light of the appr opriate standard set forth in Instruction 4 to Item
402(b) of Regulation S-K
*    *    *    *

Mr. Thomas N. Konatich
SIGA Technologies, Inc.  November 26, 2008 Page 4

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that  keys your responses to our
comments and provide the requested information.  Detailed letters gr eatly facilitate our
review.  Please furnish your letter on 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 co mments, 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities 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 comments on your filing.
You may contact Ibolya I gnat, Staff Accountant at  (202) 551-3656, or Mark
Brunhofer, Senior Staff Acc ountant, at (202) 551-3638 if you have any questions
regarding the processing of your response as well as any questions regarding comments
on the financial statements and related matte rs.  You may contact Sonia Barros, Senior
Staff Attorney at (202) 551-3655 regarding other comments.  In this regard, do not
hesitate to contact me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg
Senior Assistant Chief
Accountant