SecProbe.io

June 29, 2010
  Harry S. Palmin President and Chief Executive Officer Novelos Therapeutics, Inc.
One Gateway Center, Suite 504
Newton, Massachusetts 02458
 Re: Novelos Therapeutics, Inc.
Amendment No. 1 to Registrati on Statement on Form S-1
Filed June 25, 2010 File No. 333-166744

Dear Mr. Palmin:   We have considered your amended regist ration statement and co rrespondence filed on
June 25, 2010 to our comment letter dated May 14, 2010 and have the following comment.     Please respond to this letter by amending your registration statement and providing the
requested information.  Where you do not believe our comment applies to your facts and circumstances or do not believe that an amendm ent is appropriate, please tell us why in your
response.
After reviewing any amendment to your re gistration statement and the information you
provide in response to this comment,  we may have additional comments.

Form S-1

1. We note that you have omitted certain informati on from the prospectus in relation to the
terms of your offering.  Please revise your  prospectus to include the following
information:
• The number of units to be sold in the offering;
• The number of shares of common stock and warrants per unit;
• The number of shares purcha sable under the warrants;
• The exercise price of the warrants; and
• The exercise period for the warrants.

Please note that we will not be in a position to act on a request for acceleration of effectiveness until the requested informati on has been provided in the prospectus.

Harry S. Palmin
Novelos Therapeutics, Inc. June 29, 2010 Page 2

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes all information require d under the Securities Act
of 1933 and all applicable Securi ties Act rules.  Since the comp any and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.       Notwithstanding our comments, in the event you  request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:
• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

• the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.  Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

 Please contact Bryan Pitko at (202) 551- 3203 or Suzanne Hayes at (202) 551-3675 with
any questions.  In this regard, please fr ee to contact me at (202) 551-3715.

      Sincerely,
        J e f f r e y  P .  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  Matthew Eckert
Foley Hoag LLP 155 Seaport Boulevard Boston, Massachusetts 02210