United States securities and exchange commission logo May 20, 2024 Michael Tardugno Executive Chairman of the Board Imunon, Inc. 997 Lenox Drive, Suite 100 Lawrenceville, New Jersey 08648 Re: Imunon, Inc. Registration Statement on Form S-3 Filed May 15, 2024 File No. 333-279425 Dear Michael Tardugno: 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 Jimmy McNamara at 202-551-7349 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Megan Gates