May 13, 2014

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-6010

Re: Galena Biopharma, Inc.; Registration Statement on Form S-3 (Reg. No. 333-195260)

Ladies and Gentlemen:

On behalf of Galena Biopharma, Inc. (“Galena”), the undersigned hereby requests that the Securities and Exchange Commission issue an order declaring the above-referenced Registration Statement effective at 5:00 P.M., Washington, D.C. time, on Thursday, May 15, 2014, or as soon thereafter as is practicable.

In making its request, Galena acknowledges that:

• should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, that act will not foreclose the Commission from taking any action with respect to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective does not relieve Galena from its full responsibility for the adequacy and accuracy of the disclosures in the Registration Statement; and

• Galena may not assert staff comments or 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.

Securities and Exchange Commission

May 13, 2014

Page 2

Galena also understands that this request for acceleration will be considered a confirmation of its awareness of its obligations under the Securities Act of 1933 and the Securities Exchange Act of 1934 with respect to the offering of securities pursuant to the Registration Statement.

Very truly yours,

/s/ Mark J. Ahn, Ph.D.

Mark J. Ahn

President and Chief Executive Officer