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    kl03036.htm

    420
Lexington Avenue - Suite 408

    New
York, NY 10170

    March 26,
2008

    VIA
EDGAR

    Mr. Jim
B. Rosenberg

    Senior
Assistant Chief Accountant

    United
States Securities and Exchange Commission

    Division
of Corporation Finance

    100 F
Street, N.E.

    Washington,
D.C. 20549

              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.
Rosenberg:

    Reference
is made to the letter (the “Comment Letter”), dated November 26, 2008, setting
forth the comments of the staff (the “Staff”) of the Division of Corporation
Finance of the Securities and Exchange Commission (the “SEC”) regarding the
filings of SIGA Technologies, Inc. (“SIGA,” the “Company” or “we”) referenced
above.

    This
letter contains the Company’s responses to the additional Staff’s comment
communicated to us verbally by Ms. Ignat on March 16, 2009.  For your
convenience, the Staff’s comment has been restated below in its entirety, with
the response to the comment set forth immediately under the
comment.

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

    Consolidated Financial
Statements (Unaudited)

    3.  Stockholders’
Equity, page 8

              1.

              We
      acknowledge your response to prior Comment 3, please revise your
      disclosure to clarify the accounting treatment for the deferred
      transaction cost of $581,358 in the event  you do not issue stock
      under the M&F Letter Agreement .  Please also tell us what
      consideration you have given to writing off the deferred transaction costs
      due to the potential abandonment of the
  offering.

    In our
Form 10-Q for the quarter ending March 31, 2009, we will expand our disclosure
to clarify the accounting treatment of the deferred transaction costs related to
the M&F Letter Agreement.  Specifically, we will
disclose  that in the event that we do not issue stock under the
M&F Letter Agreement, we will charge the entire amount of deferred
transaction costs to the results of operations at the end of our agreement with
M&F.  We respectfully advise the staff that the agreement with
M&F will remain in effect until the issuance of stock as provided in the
M&F Letter, abandonment of the agreement mutually by both parties or until
such Letter’s expiration.  At the current time, there is no plan to
abandon this transaction.  In the event that the transaction provided
for in the M&F Letter is abandoned, we will charge the entire amount of
deferred transaction costs to the results of operations at such
point.

    _______________

    2

    We trust
that the preceding responses will fully address the Staff’s additional comment
as provided orally by Ms. Ignat.  Additionally, the Company
acknowledges that:

              o

              the
      Company is responsible for the adequacy and accuracy of the disclosure in
      the filing;

              o

              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

              o

              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.

    If you
have any questions or comments regarding the Company’s responses, please do not
hesitate to contact me.

                        Very truly
yours,

                        /s/ Ayelet
Dugary

                        Ayelet
Dugary

                        Acting Chief
Financial Officer

                        SIGA Technologies,
Inc.

    3