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Mail Stop 6010          April 16, 2009  Dr. Garo H. Armen, Ph.D.  Chairman and Chief Executive Officer  Antigenics, Inc.  3 Forbes Road  Lexington, MA 02421

Re: Antigenics, Inc.
 Preliminary Proxy Statement on Schedule 14A  Filed April 9, 2009  File Number 000-29089

Dear Dr. Armen:

We have limited our review of your filing to the issue we have addressed in our
comment below.  Where indicated, we think you should revise your document in response to this comment.  If you disagree, we  will consider your e xplanation as to why
our comment is inapplicable or a revision is unnecessary.  Please be as detailed as
necessary in your explanations.     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 comment or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Preliminary Proxy Statement filed April 9, 2009

1. Please disclose whether you currently have, or do not have, any plans to issue any
of the authorized but unissued shares th at would be available as a result of the
approval of the amendment to the Am ended and Restated Certificate of
Incorporation to effect a reverse stock split of your outstanding shares of common stock.

* * * * *

Dr. Garo H. Armen, Ph.D.
Antigenics, Inc.  April 16, 2009 Page 2   As appropriate, please amend your filing and respond to this comment within 10
business days or tell us when you will provide  us with a response.  You may wish to
provide us with marked copies of the amendm ent to expedite our review.  Please furnish
a cover letter with your amendment that keys your response to our comment and provides any requested information.  Detailed cover lett ers greatly facilitate our review.  Please
understand that we may have additional comm ents after reviewing your amendment and
response to our comment.   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.
  Notwithstanding our comments, in the ev ent the company requests acceleration of
the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that:
• should the Commission or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;

• the action of the Commission or the staff,  acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the company from its full
responsibility for the adequacy  and accuracy of the disclosure in the filing; and

• the company may not assert this action as  a defense in any proceeding initiated by
the Commission or any person under the fe deral securities laws of the United
States.

 In addition, please be advi sed that the Division of En forcement 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.    Please contact Rose Zukin at (202) 551-3239 or me at (202) 551-3710 with any
questions.         S i n c e r e l y ,            J e f f r e y  P .  R i e d l e r         A s s i s t a n t  D i r e c t o r