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                          December 5, 2022

       Kenneth A. Berlin
       President and Chief Executive Officer
       Advaxis, Inc.
       9 Deer Park Drive, Suite K-1
       Monmouth Junction, New Jersey 08852

                                                        Re: Advaxis, Inc.
                                                            Registration
Statement on Form S-4
                                                            Filed November 29,
2022
                                                            File No. 333-268586

       Dear Kenneth A. 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 Alan
Campbell at 202-551-4224 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              Justin W. Chairman