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Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                   October 24, 2006  Mr. Harry S. Palmin President and CEO Novelos Therapeutics, Inc. One Gateway Center, Suite 504 Newton, MA 02458

 Re: Novelos Therapeutics, Inc.
 Item 4.02(a) Form 8 -K filed October 24, 2006
 File No. 333-119366

Dear Mr. Palmin:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comments are inapplicable
or revisions are unnecessary.
  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 number listed at  the end of this letter.
 Item 4.02 (a) Form 8-K filed October 24, 2006

1. Please tell us whether you have reconsid ered, in accordance with Item 307 of
Regulation S-B, the adequacy of your pr evious assertions in your September 30,
2005 Form 10-QSB and December 31, 2005 Form 10-KSB regarding your disclosure controls and pro cedures, particularly in light  of the restatement issue
that you have described in this 8-K.

Mr. Harry S. Palmin
Novelos Therapeutics, Inc. October 24, 2006 Page 2
 2. Please also provide us with an estimated time-frame as to when you intend to file
the Form 10-QSB/A for the period ended September 30, 2005 and the Form 10-KSB/A for the year ended December 31, 2005.

*    *    *    *
Please provide us the information requested within 5 business days of the date of
this letter or tell us when you will provide a response prior to the expiration of the 5-day
period. Detailed letters greatly f acilitate our review.  You shou ld furnish the letter to us
via EDGAR under the form type label CORRESP .  Please understand that we may have
additional comments after reviewin g your response to our comment.

 We urge all persons who are responsible  for the accuracy and adequacy of the
disclosure in the filing to be certain that  they have provided all information required
under the Securities Exchange Act of 1934 and that 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:
• 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 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 advise d that the Division of Enfo rcement 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.

If you have any questions, please do not hesitate to call me at (202) 551-3657.

 Sincerely,
          A m y  C .  B r u c k n e r          S t a f f  A c c o u n t a n t