United States securities and exchange commission logo September 2, 2021 Kenneth A. Berlin President and Chief Executive Officer Advaxis, Inc. 9 Deer Park Drive, Suite K-1 Monmouth Junction, NJ 08852 Re: Advaxis, Inc. Registration Statement on Form S-4 Filed August 25, 2021 File No. 333-259065 Dear Mr. Berlin: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact David Gessert at 202-551-2326 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences