Mail Stop 4561

      April 25, 2006

Joseph S. Tibbetts, Jr.
Senior Vice President, Chief Financial Officer
and Principal Accounting Officer
Novell, Inc.
404 Wyman Street, Suite 500
Waltham, MA 02451

	Re:	Novell, Inc.
   Form 10-K for the Fiscal Year Ended
   October 31, 2005
		Filed January 10, 2006
   Forms 8-K Filed December 1, 2005 and March 2, 2006
		File No. 000-13351

Dear Mr. Tibbetts:

	We have reviewed your response to our letter dated March 31,
2006 in connection with our review of the above referenced filings
and have the following comments.  Please note that we have limited
our review to the matters addressed in the comments below.  We may
ask you to provide us with supplemental information so we may
better
understand your disclosure.  Please be as detailed as necessary in
your explanation.  After reviewing this information, we may raise
additional comments.

      Please understand that the purpose of our review 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 10-K For the Fiscal Year Ended October 31, 2005

Consolidated Statements of Operations, page 51

1. We note the Company recorded gain on settlement of potential
litigation of approximately $448,000 million as a credit to
operating
expenses.  Tell us the basis for recording litigation settlement
within operating expenses.  Further explain the basis for
recording
the settlement all in one year (i.e. are there any contingencies
or
future performance required by the Company relating to this
settlement).

      * * * * *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing any amendment and your responses to our comments.

	You may contact Patrick Gilmore at (202) 551-3406, Thomas
Ferraro at (202) 551-3225 or me at (202) 551-3730 if you have
questions regarding comments on the financial statements and
related
matters.

							Sincerely,


							Kathleen Collins
							Accounting Branch Chief

Joseph S. Tibbetts, Jr.
Novell, Inc.
April 25, 2006
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