SecProbe.io

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Mail Stop 6010

      June 28, 2005

Via U.S. Mail and Facsimile to (403) 295-4901

Werner Gartner
Principal Financial Officer
Novatel, Inc.
1120 - 68th Avenue N.E.
Calgary, Alberta, Canada
T2E 8S5

	Re:	Novatel Inc.
		Form 20-F for the Year Ended December 31, 2004
		Filed May 24, 2005
      File No. 000-29004

Dear Mr. Gartner:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  In some of our comments, we may ask
you
to provide us with information so we may better understand your
disclosure.  After reviewing this information, we may raise
additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 20-F for the Fiscal-Year Ended December 31, 2004

Item 15. Controls and Procedures, page 67

1. We note your disclosure that management has concluded that your
disclosure controls and procedures are "effective and designed to
ensure that material information relating to the Company should be
made known to them by others within those entities."  The language
that is currently included after the word "effective" in your
disclosure appears to be superfluous, since the meaning of
"disclosure controls and procedures" is established by Rule 13a-
15(e)
of the Exchange Act.  However, if you do not wish to eliminate
this
language, please revise future filings so that the language that
appears after the word "effective" is substantially similar in all
material respects to the language that appears in the entire two-
sentence definition of "disclosure controls and procedures" set
forth
in Rule 13a-15(e).

Note 2 Significant Accounting Policies, page F-8

n) Investment Tax Credits, page F-11

2. We see on page F-5 that in 2004 you recorded a benefit from
investment tax credits of CDN$4.4 million and see you presented
this
amount as income from continuing operations before income taxes.
Please respond in detail to the following:
* We note you account for investment tax credits using the cost
reduction method under Canadian generally accepted accounting
principles.  Please tell us how U.S. generally accepted accounting
principles requires you to account for the recognition of the
investment tax credits. Provide an enhanced discussion of the
events
that occurred which lead to its recognition and the journal
entries
you recorded in connection with the 2004 investment tax credit
transactions. Additionally, please cite the accounting literature
upon which you relied to support your U.S. generally accepted
accounting principles accounting requirements for investment tax
credits.
* We also note that you have presented the investment tax credit
benefit as part of income from continuing operations before income
taxes. Please explain how you determined this was the proper
presentation of the benefit under U.S. generally accepted
accounting
principles and cite the authoritative literature upon which you
relied to make this conclusion.

Consider the need to revise Note 22 to quantify and disclose all
accounting and presentation differences between U.S. and Canadian
generally accepted accounting principles. We may have further
comments based on your response.

       As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your responses to our
comments.

	 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 all information required under the Securities
Exchange Act of 1934 that they have provided all information
investors require for an informed decision.  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 connection with responding to our comments, please
provide,
in writing, a 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 securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Kevin Kuhar, Staff Accountant, at (202) 551-
3662 or me at (202) 551-3603 if you have questions regarding these
comments on the financial statements and related matters.  In this
regard, do not hesitate to contact Angela Crane, Branch Chief, at
(202) 551-3554.

								Sincerely,

								Jay Webb
								Reviewing Accountant

Werner Gartner
Novatel, Inc.
June 28, 2005
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