SecProbe.io

July 31, 2014

Via E -Mail
Daniel J. Luckshire
Executive Vice President and  Chief Financial Officer
SIGA Technologies, Inc.
660 Madison Avenue, Suite 1700 10065
New York, NY

Re: SIGA Technologies, Inc.
 Form 10-K for the year ended December 31, 2013
Filed March 10, 2014
File No. 000 -23047

Dear Mr. Luckshire :

We have reviewed your filing an d 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 advising us when you will provide the requested
response.   If you do not  believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, w e may have  additional comments.

Item 1. Business
Lead Product - Arestvyr™, page 2

1. We note that in 2013 you received $109.7 million from BARDA for the delivery of
725,000 courses of Arestvyr™ under the BARDA Contract and that you have deferred  all
revenue except certain amounts related to BARDA’s reimbursement of research and
development costs.  As disclosed on page 32, the BARDA Contract is a multiple
deliverable arrangement  and you have not satisfied all obligations necessary to recognize
revenue attributable to these delivered courses. Please expand your discussion of the
BARDA Contract in the Business section to disclose all material terms. These terms
would include all material rights and obligations, including all material deliverables.
Discuss the progress made to date towards meeting the obligations necessary for
recognition of this revenue.  Also disclose the terms of the agreement related to
BARDA’s obligation to make payments. These would include milestone payments,
reimbursements, an d any other payment obligations.

Daniel J. Luckshire
SIGA Technologies, Inc .
July 31, 2014
Page 2

Manufacturing, page 3

2. We note that in 2013 you received approximately $109.7 million from BARDA for the
delivery of approximately 725,000 courses of Arestvyr™. We also note that you depend
on contract manufacturers to pro vide this product. Please amend your disclosure to
identify the manufacturer(s) and disclose the materials terms of your agreement(s) related
to the manufacture of Arestvyr™.  Please file these agreements as exhibits to your 10 -K.
Alternatively, please pro vide your analysis as to why you are not required to file these
manufacturing agreements as exhibits to your 10 -K.

Intellectual Property and Proprietary Rights, page 6

3. For each material issued patent  disclose the type of patent  issued and the protecti on
conferred such as composition of matter, method of use, method of manufacturing, etc.
Also expand the disclosure  to clarify the products or treatments that apply to each of your
material issued patents.

Properties, page 27

4. We note that in 2 013 you subleased your New York headquarters for $720,000 and
lease d your research and development facilities in Oregon for $900,000. Please file these
material leases as exhibits to the 10 -K.  Alternatively, please provide your analysis as  to
why you are not required to file them as exhibits to your 10 -K.

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 Exchan ge Act of
1934 and all applicable Exchange 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 adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written 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 comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the Un ited States.

Daniel J. Luckshire
SIGA Technologies, Inc .
July 31, 2014
Page 3

 Please contact Johnny Gharib  at (202) 551 -3170, Amy Reischauer at 202 -551-3793 or me
at (202) 551 -3715 with any questions.

Sincerely,

 /s/ Jeffrey P. Riedler

Jeffrey P. Riedler
Assistant Director