Bank
of America Plaza
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813.229.7600
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101
East Kennedy Boulevard
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813.229.1660
fax
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Suite
2800
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Tampa,
Florida 33602
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www.slk-law.com
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Re:
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Oragenics,
Inc.
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Form
10-K for Fiscal year ended December 31, 2008
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As
Amended on April 29, 2009
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Form
10-Q for the quarterly period ended March 31, 2009
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Filed
May 20, 2009
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File
No. 001-32188
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1.
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The
certifications filed are not dated as required by Item 601(b)(31) of
Regulation S-K. Please file an amendment to the Form 10-K that
includes the entire Part III information and new, corrected certifications
signed by your current chief executive officer and chief financial
officer.
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Response:
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The
Form 10-K amendment is being filed contemporaneously with this letter
including the entire Part III with the dated certifications signed by the
current chief executive officer and chief financial
officer.
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2.
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Please
tell us why these certifications do not include the entire introductory
language of paragraph 4 to also address your officers’ responsibility for
establishing and maintaining internal control over financial
reporting.
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Response:
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The
Form 10-Q inadvertently omitted the complete introductory language
addressing the officers’ responsibilities for establishing and maintaining
internal controls. As the acting Chief Executive Officer and
Chief Financial Office at the time of the original filing and
as the current Chief Executive Officer, Mr. David Hirsch acknowledges that
he had responsibility for establishing and maintaining internal control
over financial reporting. In addition, the Company advises the Staff
that the omitted certification language will be included in future
filings.
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Sincerely,
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/s/Mark A. Catchur
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Mark
A. Catchur, Partner
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