March 18, 2025

Harry Kirsch
Chief Financial Officer
Novartis AG
Postfach CH-4002 Basel
Switzerland

       Re: Novartis AG
           For 20-F for Fiscal Year Ended December 31, 2024
           Filed January 31, 2025
           File No. 001-15024
Dear Harry Kirsch:

       We have reviewed your filing and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

For 20-F for Fiscal Year Ended December 31, 2024
3.D Risk Factors
Intellectual Property, page 10

1.     You state on page 35 that Entresto patent protection is set to expire in
2025 and 2026
       in the US and EU, respectively and that, based on your disclosure on
page 41,
       Entresto makes up USD 7.8 billion in net sales. In future filings,
please expand your
       risk factor disclosure to discuss specific risks that may result based
on Entresto's
       imminent patent expiration.
Novartis consolidated financial statements for the fiscal year ended December
31, 2024
Note 3. Operating segment, page F-17

2.     We note you operate as a single global operating segment company due to
the spin-off
       of the Sandoz business on October 3, 2023. We also note on page 21 that
you have
       two commercial units, US and International. Please explain to us how you
concluded
       that you operate as a single operating segment. Refer to IFRS 8.11
12.
       We remind you that the company and its management are responsible for
the accuracy
 March 18, 2025
Page 2

and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

       Please contact Lynn Dicker at 202-551-3616 or Daniel Gordon at
202-551-3486 if
you have questions regarding comments on the financial statements and related
matters. Please contact Doris Stacey Gama at 202-551-3188 or Chris Edwards at
202-551-
6761 with any other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Life
Sciences