August 8, 2024

Michael Poirier
Chief Executive Officer
Qualigen Therapeutics, Inc.
5857 Owens Avenue, Suite 300
Carlsbad, CA 92008

       Re: Qualigen Therapeutics, Inc.
           Amendment No. 3 to Registration Statement on Form S-1
           Filed August 7, 2024
           File No. 333-272623
Dear Michael Poirier:

     We have reviewed your amended registration statement and have the
following
comments.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe a 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 letter, we may have additional comments.

Amendment No. 3 to Registration Statement on Form S-1
General

1.     Please revise your cover page to disclose the volume of securities you
will be offering in a
       best-efforts basis as required by Item 501(b)(2) of Regulation S-K.
Given that this is a
       best-efforts, no minimum offering in which your placement agent is not
required to
       arrange for the purchase and sale of any specific number or dollar
amount of shares and
       that you may not sell the entire amount of common stock and warrants
being offered,
       please delete references to the total amount of proceeds you may receive
from the offering
       in the subheading of the prospectus. Finally, revise the legal opinion
to reference the total
       number of securities being offered rather than the dollar amount. For
additional guidance,
       refer to Securities Act Rules Compliance and Disclosure Interpretations
Question 227.02.
2.     We note your disclosure that you have engaged Univest Securities, LLC to
act as your
       placement agent in a best efforts offering. Please revise your cover
page to disclose the
       termination date of the offering. See Item 501(b)(8)(iii) of Regulation
S-K.
 August 8, 2024
Page 2

Use of Proceeds, page 21

3.     We note your intention to use approximately $1.6 million of the net
proceeds of the
       offering to repay outstanding indebtedness. However, we also note that
this is a best-
       efforts offering with no minimum offering amount. Given that this is a
best-efforts, no
       minimum offering, please revise your Use of Proceeds section to explain
how proceeds
       will be allocated in the event you raise less than the full $1.6 million
required to repay
       outstanding indebtedness.
       Please contact Doris Stacey Gama at 202-551-3188 or Jason Drory at
202-551-8342 with
any other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Life
Sciences
cc:   Ross Carmel, Esq.