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                                                                                                April 11, 2008

Mr. Christopher Naughton
Managing Director
Novogen Limited
140 Wicks Road
North Ryde, New South Wales 2113, Australia

Re:      Novogen Limited
Form 20-F for fiscal year ended June 30, 2007
File No. 0-29962

Dear Mr. Naughton:

           We have limited our review of your  filing to those issues we  have addressed in our
comments. In our comments, we ask you to provide us with information to better
understand your disclosure.  Where it requests y ou to revise disclosure, the information
you provide should show us what the revised disclosure will look like and identify the
annual or quarterly filing, as applicable, in which you intend to  first include it.  If you do
not believe that revised disc losure is necessary, explain the reason in your response.
After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.

 Please understand that the purpose of our re view 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.

Mr. Christopher Naughton
Novogen Limited
April 11, 2008 Page 2   Form 20-F for Fiscal Year Ended June 30, 2007

Item 5. Operating and Financial Review and Prospects

Application of Critical  Accounting Policies

Revenue Recognition, page 33
 1. We believe that your disclosure related to estimates of items that reduce gross
revenue, such as certain trade discounts  and returned goods, could be improved.
Please revise your disclosure to include the following information.

a) The nature and amount of each accrual at the balance sheet date and the effect
that could result from using other reas onably likely assumptions than what
you used to arrive at each accrual su ch as a range of reasonably likely
amounts or other type of sensitivity analysis.
b) The factors that you consider in estima ting each accrual such as historical
return of products, levels of inventor y in the distribution channel, estimated
remaining shelf life, price changes from competitors and introductions of generics and/or new products.
c) To the extent that information you consider  in b) is quantifiable, discuss both
quantitative and qualitative informa tion and discuss to what extent
information is from external source s (e.g., end-customer prescription demand,
third-party market research data comparing wholesaler i nventory levels to
end-customer demand). For example, in  discussing your estimate of product
that may be returned, consider disclosing and discussing, preferably by product and in tabular format, the tota l amount of product (in sales dollars)
that could potentially be returned as of the balan ce sheet date and
disaggregated by expiration period.
d) If applicable, discuss any shipments made  as a result of incentives and/or in
excess of your customer’s ordinary course of business inventory level.  Discuss your revenue recognition policy for such shipments.
e) A roll forward of the liability for each estimate for each period presented
showing the following:
• Beginning balance,
• Current provision related to sales made in current period,
• Current provision related to sales made in prior periods,
• Actual returns or credits in current period related to sales made in current period,
• Actual returns or credits in current period related to sales made in prior periods, and

Mr. Christopher Naughton
Novogen Limited
April 11, 2008 Page 3
• Ending balance.
f) In your discussion of results of opera tions for the period to period revenue
comparisons, discuss the amount of and reason for fluctuations for each type
of reduction of gross revenue (i.e. certain trade discounts and product returns) including the effect that changes in y our estimates of these items had on your
revenues and operations.
Note 24 Differences Betw een AIFRS and U.S. GAAP

(iv) Minority interests, page 133
 2. Please tell us how your accounting for minority interests under AIFRS complies with IFRS with references to the applicable se ctions within IFRS.  In addition, please
revise your disclosure to  clarify the following:

• Your disclosure of the income/loss allo cation to minority interests appears to
indicate that these amounts are computed differently under AIFRS and US GAAP. In particular, you state that “under AIFRS minoriti es are allocated
their share of previous pr ofits, losses and reserves acco rding to the percentage
holding at year end.” However, minor ity interest on the statements of
operations for 2007 and 2006 appear to be the same under AIFRS and US GAAP.
• The amount of minority interests reco nciling shareholders’ equity using
AIFRS to US GAAP shown on page 129 a ppears to differ significantly from
the corresponding amounts shown on your balance sheets.

*    *    *    *

Please respond to the comment within 10 business days or tell us when you will
provide us with a response.  Your lette r should key your response to our comment.
Detailed cover letters greatly facilitate our review.  Please furnish your letter on EDGAR
under the form type label CORRESP.

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 in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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 co mments, please provide, in your letter, a
statement from the company acknowledging that:

Mr. Christopher Naughton
Novogen Limited April 11, 2008 Page 4
 • the company is responsible for the adequacy  and accuracy of the disclosure in the
filings;
• 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

 In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

You may contact Frank Wyman, St aff Accountant, at 202-551-3660  or Don
Abbott, Senior Staff Accountant, at 202- 551-3608, if you have questions regarding the
comment.  In this regard, do not he sitate to contact me, at 202-551-3679.

       S i n c e r e l y ,

       J i m  B .  R o s e n b e r g
      Senior Assistant Chief Accountant