Form: S-1/A

General form of registration statement for all companies including face-amount certificate companies

June 25, 2010

155 Seaport Boulevard
Boston, MA 02210-2600
 
617 832 1000 main
617 832 7000 fax

June 24, 2010
617 832 1113 direct
pbork@foleyhoag.com
 
 
 
 
Via Edgar

Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, DC  20549
Attn: Bryan J. Pitko
 
   
 
Re:
Novelos Therapeutics, Inc.
Amendment No. 1 to Registration
Statement on Form S-1
File No. 333-166744                                                      
 
 
Ladies and Gentlemen:
 
This letter constitutes supplemental correspondence on behalf of Novelos Therapeutics, Inc., a Delaware corporation (the “Company”), related to and filed together with the Amendment No. 1 (the “Amendment”) to the Company’s Registration Statement on Form S-1 filed with the Securities and Exchange Commission on May 11, 2010 (as amended, the “Registration Statement”).  The Registration Statement covers the direct offering of shares of the Company’s common stock, par value $0.00001 per share (the “Common Stock”), and warrants to purchase shares of Common Stock, by the Company, such shares of Common Stock (including share underlying such warrants) not to exceed 60,000,000 in the aggregate.
 
The principal purposes of the Amendment are as follows:
 
 
·
To include the Company’s financial information for the first quarter of 2010;
 
 
·
To change the offering contemplated in the prospects from an offering solely of Common Stock to an offering of units consisting of Common Stock and warrants to purchase Common Stock;
 
 
·
To specify the termination date of the offering, July 21, 2010; and
 
 
 

 
 
Securities and Exchange Commission
June 24, 2010
Page 2
 
 
 
·
To update the disclosure as necessary to reflect events occurring since the initial filing of the Registration Statement on May 11, 2010.
 
We have transmitted under separate cover a marked copy of the Amendment comparing it to the Registration Statement as first filed with the Commission on May 11, 2010 to facilitate your review.
 
Should a member of the Staff have any questions concerning this filing, it is requested that he or she contact the undersigned, Paul Bork, at (617) 832-1113, or in my absence, Matthew Eckert at (617) 832-3057.
 
  Very truly yours,  
       
 
  /s/ Paul Bork  
    Paul Bork  
       
       
PB:mse


Mr. Harry Palmin
 
Mr. Matthew Eckert