SecProbe.io

April 8, 2014

Via E -mail
Peter Leparulo
Chairman and Chief Executive Officer
Novatel Wireless, Inc.
9645 Scranton Road
San Diego, CA 92121

Re: Novatel Wireless, Inc.
 Form 10-K for the Year Ended December 31, 2013
Filed March 12, 2014
File No. 000 -31659

Dear Mr. Leparulo:

We have reviewed your filing and have the following comments.  Please comply with the
following comments in future filings.  Confirm in writing that you will do so and explain to us
how you intend to comply.   In some of our co mments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter within ten business days by providing the requested
information or by advising us when you will provide the requested response .  If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.

Management’s Discussion and An alysis…, page 24

1. We note your recurring operating losses and net loss of $43.4 million for the year
ended December 31, 2013.  Further, we note your statement that “[your] ability to
transition to attaining profitable operations is dependent upon achieving  a level of
revenues adequate to support [your] cost structure.”  Please expand your discussion to
detail the steps management is taking to make the company profitable in the long
term.  Discuss how management specifically intends to increase revenue with the
introduction of 4G broadband -access products, M2M solutions and software
applications and platforms, and explain how management intends to lower expenses,
if applicable.

Peter Leparulo
Novatel Wireless, Inc.
April 8, 2014
Page 2

 Results of Operations, page 26

2. Please enhance the overview of your management’s discussion and analysis to
discuss the likely impact of known trends, demands, commitments, events or
uncertainties that are reasonably likely to have material effects on your financial
condition or results of operations.  Refer to Item 303(a)(3)(iii) of R egulation S -K.
For example, provide qualitative and quantitative disclosure to explain increased
market competition at your largest customer and discuss factors affecting 4G product
sales prices.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts rela ting to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for  the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comm ents as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Justin Kisner, Attorney -Adviser, at (202) 551 -3788, or Celeste M.
Murphy, Legal Branch Chief, at (202) 55 1-3257, or me at (202) 551 -3810 with any questions.

Sincerely,

 /s/ Celeste M. Murphy for

Larry Spirgel
Assistant Director

cc: Via E -mail
 Catherine F. Ratcliffe, Esq.
 General Counsel and Secretary
 Novatel Wireless, Inc.

Donna M. Petkanics
 Wilson Sonsini Goodrich & Rosati, P.C.