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CORRESP Filing

AGENUS INC
Date: May 28, 2025 · CIK: 0001098972 · Accession: 0001193125-25-129466

Offering / Registration Process

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File numbers found in text: 333-287197

Date
May 28, 2025
Author
Christine M. Klaskin
Form
CORRESP
Company
AGENUS INC

Letter

Re: Agenus Inc. Registration Statement on Form S-3 (File No. 333-287197) 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. 333-287197) (the “ Registration Statement ”), so that it will be declared effective at 4:00 p.m. Eastern Time on May 30, 2025, or as soon as possible thereafter. The Company hereby authorizes Zachary Blume 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 Zachary Blume of Ropes & Gray LLP, counsel to the Company, at (617) 951-7663.

AGENUS INC. 3 Forbes Road Lexington, MA 02421 May 28, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.W. Washington, D.C. 20549

Attention: Joshua Gorsky

Very truly yours,
AGENUS INC.

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CORRESP
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 CORRESP

 AGENUS INC.
 3 Forbes Road Lexington, MA 02421
 May 28, 2025 VIA EDGAR
 U.S. Securities and Exchange Commission Division of Corporation
Finance 100 F Street, N.W. Washington, D.C. 20549

 Attention:
   Joshua Gorsky

 Re:
 Agenus Inc.
 Registration Statement on Form S-3 (File No. 333-287197)
 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. 333-287197) (the “ Registration Statement ”), so that it will be declared effective at 4:00 p.m. Eastern Time on May 30, 2025, or as soon as possible thereafter. The Company hereby
authorizes Zachary Blume 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 Zachary Blume of Ropes &
Gray LLP, counsel to the Company, at (617) 951-7663.

 Very truly yours,

 AGENUS INC.

 By:

 /s/ Christine M. Klaskin

 Christine M. Klaskin

 Vice President, Finance