SecProbe.io

December 13, 2010
 Eric A. Rose, M.D. Chief Executive Officer SIGA Technologies, Inc. 35 East 62
nd Street
New York, NY 10065

Re: SIGA Technologies, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2009
Filed March 10, 2010 File No. 000-23047

Dear Dr. Rose:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Definitive Proxy Statement on Schedule 14A

 Annual Incentive Compensation, page 17

1. Please provide draft disclosure for an amendment that explains the Compensation
Committee’s basis for awarding Dr. Hr uby the $75,000 discretionary bonus.
Notwithstanding that the award was discretio nary, you are still required to disclose the
committee’s reasoning in making the award.
 Long-Term Incentive Awards, page 17

2. Please provide draft disclosure for an amendm ent that discusses the stock option awards
made to Ms. Dugary and Dr. Hruby in 2009, including the material performance factors considered by the Compensation Committee in determining how many options to award, the Committee’s assessment of Ms. Dugary  and Dr. Hruby with respect to those

Eric A. Rose, M.D. SIGA Technologies, Inc.  December 13, 2010 Page 2

performance factors, and how the Compensa tion Committee translated such assessment
into the specific option awards ultimately granted to these named executive officers.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure 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 comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Michael Ro senthall, Staff Attorney, at (202) 551-3674 or Daniel
Greenspan, Special Counsel, at (202) 551-3623 with any questions.

Sincerely,

  Jeffrey P. Riedler Assistant Director