February 4, 2020 Brad J. Powers, Esq. General Counsel NewLink Genetics Corporation 2503 South Loop Drive Ames, IA 50010 Re: NewLink Genetics Corporation Preliminary Proxy Statement on Schedule 14A Filed November 20, 2019 File No. 001-35342 Dear Mr. Powers: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Life Sciences cc: James C.T. Linfield, Esq.