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SEC Company Response from AGENUS INC (AGEN) (CIK 0001098972) (AGEN) — Nov 19, 2019

AGENUS INC (AGEN) (CIK 0001098972)
Date: Nov. 19, 2019 · CIK: 0001098972 · Accession: 0001193125-19-295767

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File numbers found in text: 333-234333

Date
November 19, 2019
Author
Evan D. Kearns
Form
CORRESP
Company
AGENUS INC (AGEN) (CIK 0001098972)

Letter

AGENUS INC.

3 Forbes Road

Lexington, MA 02421

November 19, 2019

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.W.

Washington, D.C. 20549

Attention: Mary Beth Breslin

Irene Paik

Re: Agenus Inc.

Registration Statement on Form S-3 (File No. 333-234333)

Request for Acceleration

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Agenus Inc. (the “Company”) hereby requests that the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the Company’s Registration Statement on Form S-3 (File No. 333-234333) (the “Registration Statement”), so that it will be declared effective at 4:00 p.m. Eastern Time on November 22, 2019, or as soon as possible thereafter. The Company hereby authorizes Zachary Blume and Rachael Diament of Ropes & Gray LLP, counsel to the Company, to orally modify or withdraw this request for acceleration.

It would be appreciated if, as soon as the Registration Statement is declared effective, you would inform Rachael Diament of Ropes & Gray LLP, counsel to the Company, at (212) 596-9159.

Very truly yours,
AGENUS INC.

Show Raw Text
CORRESP
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filename1.htm

CORRESP

 AGENUS INC.

3 Forbes Road

 Lexington, MA 02421

 November 19, 2019

 VIA EDGAR

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street, N.W.

 Washington, D.C. 20549

Attention:
 Mary Beth Breslin

Irene Paik

Re:
 Agenus Inc.

Registration Statement on Form S-3 (File No. 333-234333)

 Request for Acceleration

 Ladies
and Gentlemen:

 Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Agenus Inc. (the “Company”)
hereby requests that the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the Company’s Registration Statement on Form S-3 (File No. 333-234333) (the “Registration Statement”), so that it will be declared effective at 4:00 p.m. Eastern Time on November 22, 2019, or as soon as possible thereafter. The Company hereby
authorizes Zachary Blume and Rachael Diament of Ropes & Gray LLP, counsel to the Company, to orally modify or withdraw this request for acceleration.

It would be appreciated if, as soon as the Registration Statement is declared effective, you would inform Rachael Diament of Ropes &
Gray LLP, counsel to the Company, at (212) 596-9159.

 Very truly yours,

 AGENUS INC.

 By:

 /s/ Evan D. Kearns

Evan D. Kearns

VP & General Counsel