SecProbe.io

April 25, 2013

Via E -mail
Dr. John N. Bonfiglio
Chief Executive Officer and President
Oragenics, Inc.
4902 Eisenhower Boulevard, Suite 125
Tampa, Florida 33634

Re: Oragenics, Inc.
Post-Effective Amendment No. 1 on Form S -3 to a Registration Statement on
Form S -1
Filed  April 23, 2013
  File No.  333-183685

Dear Dr. Bonfiglio :

We have limited our review of your registration statement to those issues we have
addressed in our comment .

Please respond to this letter by amending your registration statement and providing the
requested information .  Where you do not believe our comment  applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to this comment , we may have  additional comments.

Information Incorporated by Reference, page 38

1. We note that your registration statement incorporates by reference your annual report on
Form 10 -K for the year ended December 31, 2012.   This filing does not contain the Part
III information that is required by Form 10 -K.  Please amend your registration statement ,
amend your Form 10 -K filing, or file your definitive proxy statement to include the
required  Part III information.   Your filing must be complete before we take final action
on the registration statement.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   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 dis closures they have made.

Dr. John N. Bonfiglio
Oragenics, Inc.
April 25, 2013
Page 2

 Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant t o delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effect iveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceler ation of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

  Please contact Matthew Jones  at (202) 551 -3786  or me at (202) 551 -3715  with any other
questions.

Sincerely,

 /s/ Jeffrey P. Riedler

 Jeffrey P. Riedler
Assistant Director

cc: Mark A. Catchur
 Shumaker, Loop & Kendrick, LLP
 101 East Kennedy Boulevard
 Suite 2800
 Tampa, Florida 33602