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                     FLEXIBLE SOLUTIONS INTERNATIONAL, INC.
                              615 Discovery Street
                           Victoria, British Columbia,
                                 Canada V8T 5G4


                                October 30, 2009



Jessica Kane
Securities and Exchange Commission
Mail Stop 4631
100 F Street, NE
Washington, DC 20549

      Re:   CEL-SCI Corporation
            Form S-3
            File No. 333-158962

     Flexible Solutions  International,  Inc. (the "Company")  requests that the
effective date of the above captioned  Registration  Statement be accelerated to
November 4, 2009, 11:00 a.m. Eastern time, or as soon as practicable thereafter.

     The Company understands that:

     o    should the  Commission  or the staff,  acting  pursuant  to  delegated
          authority,  declare the filing  effective,  it does not  foreclose the
          Commission from taking any action with respect to the filing;

     o    the  action  of  the  Commission  or the  staff,  acting  pursuant  to
          delegated  authority,  in  declaring  the filing  effective,  does not
          relieve the Company from its full  responsibility for the adequacy and
          accuracy of the disclosure in the filing; and

     o    the  Company  may not assert 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.

                                Very Truly Yours,



                                     /s/ Daniel B. O'Brien
                                     -------------------------------------
                                     Daniel B. O'Brien, Chief Executive Officer


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