July 9, 2019

Kenneth Berlin
President and Chief Executive Officer
Advaxis, Inc.
305 College Road East
Princeton, NJ 08540

       Re: Advaxis, Inc.
           Registration Statement on Form S-1
           Filed July 2, 2019
           File No. 333-232526

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 Christine Westbrook at 202-551-5019 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Healthcare & Insurance
cc:    Kristopher D. Brown, Esq.