SecProbe.io

Mail Stop 4546

August 31 , 2016

Alan Joslyn
Chief Executive Officer  and President
Oragenics, Inc.
4902 Eisenhower Boulevard, Suite 125
Tampa, FL 33634

Re: Oragenics, Inc.
  Registration Statement on Form S -3
Filed August 25, 2016
  File No. 333-213321

Dear Mr. Joslyn :

We have limited our review of your registration statement to the issue we have addressed
in our comment.  In  our comment , we may ask you to provide us with information so we may
better understand your disclosure.

Please respond to this  letter by amending your registration statement and providing the
requested information .  If 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.

Exhibit 5.1 – Opinion of Shumaker, Loop & Kendrick, LLP

1. We note that you are registering units under the registration statement.  Please have counsel
revise the  legality opinion to cover these units.  For guidance, please see  Part II.B.1.h. of
Staff Legal Bulletin No. 19 .

We urge all persons who are responsible for the a ccuracy 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 rel ating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Alan Joslyn
Oragenics , Inc.
August 31 , 2016
Page 2

 Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement , pleas e 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 fi ling;

 the action of the Commission or the staff, acting pursuant to 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 effectiveness 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 acceleration 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 Secu rities 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 eff ective date of the
registration statement.

Please contact Josh Samples at (202) 551 -3199 or Joseph McCann  at (202) 551 -6262
with any questions.

Sincerely,

 /s/ Joseph McCann for

Suzanne Hayes
Assistant Director
Office of Healthcare and Insurance

cc: Mark A. Catchur , Esq.
 Shumaker, Loop & Kendrick, LLP