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                             November 3, 2023

       Karsten Munk Knudsen
       Executive Vice President and Chief Financial Officer
       NOVO NORDISK A/S
       Novo Alle 1
       DK-2880 Bagsv  rd
       Denmark

                                                        Re: NOVO NORDISK A/S
                                                            Form 20-F for the
fiscal year ended December 31, 2022
                                                            Response dated
October 20, 2023
                                                            File No. 333-82318

       Dear Karsten Munk Knudsen:

              We have reviewed your October 20, 2023 response to our comment
letter and have the
       following comment.

              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. Unless
       we note otherwise, any references to prior comments are to comments in
our September 27, 2023
       letter.

       Response dated October 20, 2023

       General

   1.                                                   We note your response
to prior comment 1 states that based on your enterprise risk
                                                        management process, you
have concluded that none of the identified reputational risks
                                                        related to your
operations or products that results in greenhouse gas emissions are
                                                        material. Please expand
to discuss the specific reputational risks you identified and how
                                                        you determined that
they are not material.
              Please contact Anuja A. Majmudar, Attorney-Adviser, at (202)
551-3844 or Karina
       Dorin, Attorney-Adviser, at (202) 551-3763 with any questions.
 Karsten Munk Knudsen
NOVO NORDISK A/S
November 3, 2023
Page 2

FirstName LastNameKarsten Munk Knudsen   Sincerely,
Comapany NameNOVO NORDISK A/S
                                         Division of Corporation Finance
November 3, 2023 Page 2                  Office of Life Sciences
FirstName LastName