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SEC Company Response from AGENUS INC (AGEN) (CIK 0001098972) (AGEN) — Mar 16, 2009

AGENUS INC (AGEN) (CIK 0001098972)
Date: March 16, 2009 · CIK: 0001098972 · Accession: 0001193125-09-055424

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File numbers found in text: 333-149116, 333-150326, 333-156556

Date
March 16, 2009
Author
Valentine
Form
CORRESP
Company
AGENUS INC (AGEN) (CIK 0001098972)

Letter

VIA EDGAR Division of Corporation Finance United States Securities and Exchange Commission Re: Antigenics Inc. Registration Statement on Form S-1, filed on January 2, 2009, as amended on January 27, 2009 and March 16, 2009 (File No. 333-156556) Post-Effective Amendment on Form S-1 to the Registration Statement on Form S-3, filed on January 2, 2009, as amended on March 16, 2009 (File No. 333-149116) Post-Effective Amendment on Form S-1 to the Registration Statement on Form S-3, filed on January 2, 2009, as amended on March 16, 2009 (File No. 333-150326)

Dear Mr. Pitko,

In connection with the above referenced registration statement and post-effective amendments (collectively, the “Registration Statements”), Antigenics Inc. (the “Company”) hereby acknowledges that (i) should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filings effective, it does not foreclose the Commission from taking any action with respect to the filings, (ii) the action of the Commission or the staff pursuant to delegated authority, in declaring the filings effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filings, and (iii) the Company may not assert the declaration of effectiveness as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

The Company requests effectiveness of each Registration Statement at 9:00 AM on March 18, 2009, or as soon thereafter as practicable.

Please call the undersigned at (781) 674-4400 as soon as the Registration Statements have been declared effective.

Best regards,
/s/ Karen Higgins
Valentine

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CORRESP
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SEC Letter

 March 16, 2009

 VIA EDGAR

 Mr. Bryan Pitko

 Division of Corporation Finance

 United States Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549-0306

Re:
Antigenics Inc.

 Registration Statement on Form
S-1, filed on January 2, 2009, as amended on January 27, 2009 and March 16, 2009 (File No. 333-156556)

 Post-Effective
Amendment on Form S-1 to the Registration Statement on Form S-3, filed on January 2, 2009, as amended on March 16, 2009 (File No. 333-149116)

 Post-Effective Amendment on Form S-1 to the Registration Statement on Form S-3, filed on January 2, 2009, as amended on March 16, 2009 (File No. 333-150326)

 Dear Mr. Pitko,

 In connection with the above
referenced registration statement and post-effective amendments (collectively, the “Registration Statements”), Antigenics Inc. (the “Company”) hereby acknowledges that (i) should the Securities and Exchange
Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filings effective, it does not foreclose the Commission from taking any action with respect to the filings, (ii) the action of the
Commission or the staff pursuant to delegated authority, in declaring the filings effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filings, and (iii) the Company may not
assert the declaration of effectiveness as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 The Company requests effectiveness of each Registration Statement at 9:00 AM on March 18, 2009, or as soon thereafter as practicable.

 Please call the undersigned at (781) 674-4400 as soon as the Registration Statements have been declared effective.

 Best regards,

 /s/    Karen Higgins
Valentine

 Karen
Higgins Valentine

 Vice President and General Counsel

Cc:
Garo Armen, Chairman and CEO

 Paul Kinsella,
Ropes & Gray LLP