SecProbe.io

Mail Stop 6010          July 24, 2007   Harry S. Palmin President and Chief Executive Officer Novelos Therapeutics, Inc. One Gateway Center, Suite 504 Newton, Massachusetts 02458
 Re: Novelos Therapeutics, Inc.
  Supplemental Correspondence Submitted July 13, 2007
  Registration Statement on Form SB-2   File No. 333-143263

Dear Mr. Palmin:   We have reviewed your filing and have the following comment.  Where indicated,
we think you should revise your document in response to the comment .  If you disagree,
we will consider your explanation as to why our  comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your explanation.
  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.
 FORM SB-2

1. We note your response to our comment.  However, given the nature and size of
this offering—in particular, the fact that  the shares you are registering total more
than 60% of the shares held by non-affiliates—the offering appears to be a primary offering.  Therefore, unless you re vise the nature a nd/or size of this
offering, you will need to do the following:

Harry S. Palmin
Novelos Therapeutics, Inc. July 24, 2007 Page 2
• file a registration statement for the “resale” offering at the time of each
conversion of preferred stock or exer cise of warrants because you are not
eligible to conduct the offering on a de layed or continuous basis under Rule
415(a)(1)(x);
• register the transaction on the form you are eligible to use to register the
transaction as a primary offering (either Form SB-2 or Form S 1);
• identify the selling shareholders as u nderwriters in the registration statement;
and
• include the price at which the underw riters will sell the securities.

* * *
  As appropriate, please amend your regist ration statement in response to this
comment.  You may wish to provide us with ma rked copies of the amendment to expedite
our review.  Please furnish a c over letter with your amendment that keys your response to
our comment and provides any requested info rmation.  Detailed cover letters greatly
facilitate our review.  Please understand th at we may have additional comments after
reviewing your amendment a nd response to our comment.
  We direct your attention to Rules 46 0 and 461 regarding requesting acceleration
of a registration statement.  Please allow ad equate time after the filing of any amendment
for further review before submitting a request for acceleration.  Please provide this request at least two business days in a dvance of the requested effective date.
  Please contact Greg Belliston at ( 202) 551-3861, Suzanne Hayes at (202) 551-
3675, or me at (202) 551- 3715 with any questions.
         S i n c e r e l y ,             J e f f r e y  R i e d l e r          A s s i s t a n t  D i r e c t o r   cc: Paul Bork, Esq.  Foley Hoag LLP  155 Seaport Boulevard  Boston, Massachusetts 02110