SecProbe.io

July 7, 2010

Brian Bohunicky  Chief Financial Officer, Secretary and Treasurer Oragenics, Inc. 13700 Progress Boulevard Alachua, Florida  32615
Re: Oragenics, Inc.  Schedule 14A
Filed June 29, 2010 File No. 001-32188
 Dear Mr. Bohunicky:
 We have limited our review of the above proxy st atement to the issues identified below.
In some of our comments, we may ask you to pr ovide us with information so we may better
understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

1. On page 11, you disclose that because the number of issued and outstanding shares of common stock will decrease as result of the reverse stock split, the number of authorized but unissued shares of common stock may increase on a relative basis.  Please explain how this may occur as you also state on page 11 that the number of authorized shares of common stock will be reduced.  For example, will the reverse stock split ratio of the
outstanding shares of common st ock be a different ratio than  the authorized shares of
common stock?

2. If the number of authorized but unissued shares of common stock may increase on a
relative basis, please disclose whether you cu rrently have, or do not have, any plans to
issue any of the additional shares  that would be authorized bu t unissued as a result of the
approval of the reverse stock split.
3. Please revise your disclosure to remove any inconsistencies.
• On page 8, you disclose that you are seeki ng to approve a reverse stock split at a
ratio of not less than one-for-six and not more than one-for-twenty statement.  On

Brian Bohunicky
Oragenics, Inc.
 July 7, 2010  Page 2

page 11 and elsewhere in the proxy statem ent, however, you disclose that you are
seeking to approve a reverse stock split at a ratio of not less than one-for-two and
not more than one-for-twenty.
• On page 10, you disclose that your board ma y elect to effect any one of the four
reverse split ratios.  On page 11, however , you provide examples of the effects of
the implementation of seven different ranges.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Jennifer Rieg el at (202) 551-3575 or me at (202) 551-3715 with any
questions.
Sincerely,

Jeffrey Riedler Assistant Director