December 6, 2019

Orin Hirschman
President
Novint Technologies, Inc.
100 Merrick Road, Suite 400W
Rockville Centre, NY 11570

       Re: Novint Technologies Inc.
           Registration Statement on Form 10-12G
           Filed November 14, 2019
           File No. 000-51783

Dear Mr. Hirschman:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

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

Form 10-12G filed November 14, 2019

Business, page 1

1.    Please disclose the material terms of your current licensing agreements,
including but not
      limited to, the identity of the parties, termination provisions,
restrictions and obligations,
      and minimum payments under the agreements.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Overview, page 8

2.    We note that the company has not generated revenue but your disclosure in
the filing
      suggests that you have made sales. For example, on page 5, you state that
"Novint has
      continued selling small amounts of Falcons and related software and
accessories." You
      further state on page 8 that the company's sales of its haptic products
are primarily to
      consumers through retail outlets. Please clarify the current operations
of the company
      and whether you have made any sales since 2017.
 Orin Hirschman
Novint Technologies, Inc.
December 6, 2019
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources, page 11

3.    Please revise to disclose the minimum period of time that you will be
able to conduct
      planned operations using only currently available capital resources.
Refer to FRC
      501.03(a) and Section IV of SEC Release No. 33-8350.
Security Ownership of Certain Beneficial Owners & Management, page 12

4.    Please disclose the natural person or persons who directly or indirectly
exercise sole or
      shared voting or investment control over the shares held by Congregation
Ahavas
      Tzdokah Vchesed Inc. and Alpha Capital Anstalt.
Certain Relationships and Related Transactions, and Director Independence, page
15

5.    Please revise to provide disclosure regarding your related party
transactions. We note that
      the company had issued notes to certain directors and officers which were
converted into
      common stock in 2017. Please identify the directors and officers and
discuss the material
      terms of the notes. See Instruction to Item 404 of Regulation S-K.
General

6.    Please update your financial statements to comply with Rule 8-08 of
Regulation S-X and
      provide corresponding updated disclosures throughout your filing.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact David Edgar, Staff Accountant, at (202) 551-3459 or
Melissa Kindelan,
Staff Accountant, at (202) 551-3564 if you have questions regarding comments on
the financial
statements and related matters. Please contact Michael C. Foland,
Attorney-Advisor, at (202)
551-6711 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.



                                                            Sincerely,
FirstName LastNameOrin Hirschman
                                                            Division of
Corporation Finance
Comapany NameNovint Technologies, Inc.
                                                            Office of
Technology
December 6, 2019 Page 2
cc:       Jolie Kahn
FirstName LastName