SecProbe.io

November 4, 2011
 Via E-mail

Brian J. Bohunicky Chief Financial Officer Oragenics, Inc. 3000 Bayport Drive, Suite 685 Tampa, FL 33607
Re: Oragenics, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2010
Filed March 30, 2011 File No. 001-32188

Dear Mr. Bohunicky:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide 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.
            Item 10. Directors, Executive O fficers and Corporate Governance

Director Independence, page 58

1. We note your application of NASDAQ Capital Markets listing standa rds in determining
director independence.  Please provide us with th e analysis underlying your
determination that Christine Koski and Robert  Koski are independent  within the context
of Marketplace Rule 5605(a)(2).  Your analys is should explain and specifically address
your consideration of each of their relationship with the Koski Family Limited
Partnership, your controlling shareholder and holder of more than $7 million of
promissory notes pursuant to the Credit Fac ility upon which, as you disclose on page 22,
you depend for continuing liquidity and operatio ns.  It is unclear to us how such
relationships would not preclude a determina tion that Christine Koski and Robert Koski
are independent.  Alternatively, please revise your disclosure to exclude Christine Koski
and Robert Koski from the lis t of independent directors.

Brian J. Bohunicky Oragenics, Inc. November 4, 2011 Page 2

Item 11. Executive Compensation

New 2010 Employment Agreements – Key Employees, page 64

2. Please file a copy of your employment agreemen t with Dr. Martin Ha ndfield as required
by Item 601(b)(10)(iii)(A) of Regulation S-K.

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 an d 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.

Please contact Karen Ubell at (202) 551-3873, Bryan Pitko at (202) 551-3203 or me at
(202) 551-3715 with any other questions.
Sincerely,
   /s/ Daniel Greenspan for      Jeffrey Riedler
Assistant Director