SecProbe.io

Mail Stop 4628

September 9 , 2016
Via E-Mail
Michael Newman
Executive  Vice President and Chief Financial Officer
Novatel Wireless,  Inc.
9645 Scranton Road
San Diego, CA 92121

 Re: Novatel Wireless , Inc .
  Form 10-K for the Fiscal Year Ended December 31, 2015
  Filed March 15 , 2016
  File No. 0-31659

Dear Mr. Newman :

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   In our comments , we ask you to provide us with information so we may better
understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

General

1. A May 2016 news article reports that you entered into a partnership with MTN Group to
offer Ctrack telemati cs services to MTNs Internet of Things customer base in Africa , and
that MTN Group has operations in Sudan and Syria.  Your Form 10 -K discusses
operations in Africa and the Middle East.  Sudan, in Africa and Syria, in the Middle East,
are design ated by the State Department as state sponsors of terrorism, and are subject to
U.S. economic sanctions and export controls.  Please describe to us the nature and extent
of any past, current, and anticipated contacts with Sudan and Syria, whether through
subsidiaries, affiliates, distributors, resellers, or other direct or indirect arrangements.
You should describe any products, components, technology or services you have
provided, directly or indirectly to Sudan and Syria, and any agreements, commercial
arrangements, or other contacts with the governments of those countries or entities they
control.

Michael Newman
Novatel Wireless, Inc.
 September 9 , 2016
 Page 2

 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 t he Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating 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 comments as a defense in any proceeding initiated by
the Commission or any person under the federal secur ities laws of the United States.

You may contact Jennifer Hardy, Special Counsel, at (202) 551 -3767 or me at (202) 551 -
3470 if you have any questions about the comments or our review.

Sincerely,

 /s/ Cecilia Blye

Cecilia Blye, Chief
Office of Global Security Risk

cc:  Larry Spirgel
  Assistant Director