SecProbe.io

CORRESP
1
filename1.htm

February
1, 2023

United
States Securities and Exchange Commission

Attn:
Arzhang Navai and Laura Crotty

Division
of Corporation Finance

100
F Street, N.E.

Washington,
DC 20549

    Re:
    CancerVax,
    Inc.

    Offering
    Statement on Form 1-A

    Filed
    January 12, 2023

    File
    No. 024-12130

Ladies
and Gentlemen:

CancerVax,
Inc (the “CancerVax” or the “Company”) provides the following response (the “Response Letter”) to
the comments contained in the letter (the “Comment Letter”) of the staff of the Division of Corporation Finance (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) dated January 19, 2023, relating to the above-referenced
filing.

In
response to the following enumerated comments in the Comment Letter, we respectfully submit the following responses:

Part
I

Item
3. Application of Rule 262, page i

1.
In Item 3 of Part I, we note that you have checked the box that “bad actor” disclosure under Rule 262(d) is provided in Part
II of the offering statement; however, we could not locate such disclosure. Please provide the appropriate disclosure in Part II or correct
the check box in Part I.

Response:

Thank
you for bringing this to our attention. We have updated Part I, Item 3 to remove the check mark for the “bad actor” disclosure
as there are no bad actors involved in the Company and no such disclosure is required. We have refiled Part II as well with updated dates
only.

Thank
you for your assistance and review. Please contact our legal counsel, Callie Jones, at 801-303-5721 with further comments or questions.

Sincerely,

    CancerVax,
    Inc.

    /s/
    Ryan Davies

    Ryan
    Davies

    CEO
    and Director