govx20250602_corresp.htm

On behalf of our client, GeoVax Labs, Inc., a Delaware corporation (the “Company”), we hereby confidentially submit a draft registration statement on Form S-1 (the “Registration Statement”) for non-public review by the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”). The Registration Statement relates to a proposed public offering by the Company of units consisting of shares of common stock of the Company (“Common Stock”) and warrants to purchase shares of Common Stock.

The Registration Statement is confidentially submitted to the Commission for confidential non-public review pursuant to the procedures of the Commission. The Company confirms that it will file its registration statement and nonpublic draft submission with respect to the proposed offering such that they are publicly available on the EDGAR system at least 48 hours prior to any requested effective time and date.

Should you have any questions or notifications regarding this letter or the Registration Statement, please do not hesitate to contact the undersigned, F. Reid Avett, of Womble Bond Dickinson (US) LLP, counsel to the Company, at (202) 857-4425 or Reid.Avett@wbd-us.com.

Womble Bond Dickinson (US) LLP is a member of Womble Bond Dickinson (International) Limited, which consists of independent and autonomous law firms providing services in the US, the UK, and elsewhere around the world. Each Womble Bond Dickinson entity is a separate legal entity and is not responsible for the acts or omissions of, nor can bind or obligate, another Womble Bond Dickinson entity. Womble Bond Dickinson (International) Limited does not practice law. Please see www.womblebonddickinson.com/us/legal-notice for further details.

WBD (US) 4902-6029-6775

	Very truly yours,

	/s/ F. Reid Avett
	F. Reid Avett