SecProbe.io

May 21 , 2014

Via E -mail
Garo H. Armen
Chief Executive Officer
Agenus, Inc.
3 Forbes Road
Lexington, MA 02421

Re: Agenus, Inc.
  Registration Statement on Form S-3
Filed  May 9 , 2014
  File No.  333-195852

Dear Mr. Armen :

We have limited our review of your registration statement to the resolution of your
pending confidential treatment request .  Please be advised that we will not be in a position to
declare your registration statement effective until all outstanding comments, if any, on your request
for confidential treatment have been cleared.

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 Act of 193 3 and
all applicable Securities  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.

Notwithstanding our comment , in the event you request acceleration of the effective d ate
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commissio n 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 accur acy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Garo H. Armen
Agenus , Inc.
May 21 , 2014
Page 2

 Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to rev iew any amendment prior to the requested effective date of the
registration statement.

Please co ntact J ohnny Gharib at (202) 551 -3170 or me at (202) 551 -3715 with any
questions.

Sincerely,

 /s/ Daniel  Greenspan  for

 Jeffrey P. Riedler
Assistant Director

cc: Via E -mail
Gerald E. Quirk, Esq.
Choate, Hall & Stewart LLP