SecProbe.io

Mail Stop 4546

         March  23, 2017

VIA E -mail
Mr. Harry Kirsch
Chief Financial Officer
Novartis AG
Lichtstrasse 35
4056 Basel, Switzerland

Re: Novartis AG
 Form 20-F for Fis cal Year Ended December 31, 2016
Filed  January  25, 2017
File No. 1 -15024

Dear Mr. Kirsch :

We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In our comment s, we ask you to provide us with
information so we may better understand your disclosure.

Please respond to the comment s 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 a
comment appl ies to your facts and circumstances, please tell us why in your response.

After reviewing your response to the comment s, we may have additional comments.

General

1. On your website you list offices that you maintain in Sudan and Syria, countries which
are designated by the U.S. Department of State as state sponsors of terrorism, and are
subject to U.S. economic sanctions and export controls.   Your Form 20 -F does not
include disclosure about contacts with those countries.   Please describe to us the nature
and extent of your past, current and anticipated contacts with Sudan and Syria, whether
through subsidiaries, distributors, sales representatives or other direct or indirect
arrangements.   You should describe any goods, technology, or services you have
provided into Sudan and Syria, directly or indirectly, and any agreements, arrangements
or other contacts you have had with the governments of those countries or entities they
control.

2. Please discuss the materiality of any contacts with Sudan and Syria you d escribe in
response to the comment above, and whether the contacts constitute a material

Mr. Harry Kirsch
Novartis AG
March  23, 2017
Page 2

 investment risk for your security holders. You should address materiality in quantitative
terms, including the approximate dollar amounts of any revenues, assets and l iabilities
associated with Sudan and Syria for the last three fiscal years and the subsequent interim
period.   Also, address materiality in terms of qualitative factors that a reasonable investor
would deem important in making an investment decision, inclu ding the potential impact
of corporate activities upon a company’s reputation and share value.   Various state and
municipal governments, universities and other investors have proposed or adopted
divestment or similar initiatives regarding investment in com panies that do business with
U.S.-designated state sponsors of terrorism.   You should address the potential impact of
the investor sentiment evidenced by such actions directed toward companies that have
operations associated with Sudan and Syria.

Form 20 -F for Fiscal Year  Ended December 31, 2016
5.F Tabular Disclosure of Contractual Obligations, page 169

3. Please confirm that you will include interest payments on your debt in the contractual
obligation table or in a discussion below the table in future filings.

Form 6 -K filed January 25, 2017
Exhibit 99:  Excerpts from Novartis Annual Report 2016
Notes to the Consolidated Financial Statements
Goodwill and Intangible assets, page 184 of the Annual report

4. You announced in January 2017 that you are considering options for your Alcon
Division, ranging from retaining all or part of the business to separation via a capital
market transaction such as an IPO or spin -off.  In addition, the Alcon Division incurred
operating losses for the year ended Decembe r 31, 2016 compared to operating income in
the year ended December 31, 2015.  Please provide us an analysis of the following:
 your assessment of any impairment relating to the goodwill allocated to the Alcon
division at December 31, 2016 ;
 your assessment o f any impairment related to the Alcon brand name, including how
you considered the operations in the Alcon and Innovative Medicine Divisions to
which the Alcon brand name relate in determining if an impairment was required to
be recorded pursuant to paragr aph 10 of IAS 36 ; and
 why reclassification of the Alcon brand name to Corporate activities is appropriate .

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, co mments, action or absence of
action by the staff.

Mr. Harry Kirsch
Novartis AG
March  23, 2017
Page 3

 You may contact  Mary Mast, Senior Staff Accountant , at (202) 551 -3613 or Lisa
Vanjoske, Assistant Chief Accountant, at (202) 551 -3614 with any questions .  In this regard, do
not hesitate to contact me at (202) 551 -3679.

Sincerely,

 /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant
         Office of Healthcare and Insurance