Form: CORRESP

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November 22, 2005

Via EDGAR Filing and U.S. Mail


November 22, 2005

Rufus G. Decker III
Accounting Branch Chief
United States Securities and Exchange Commission ("SEC")
100 F Street, N.E.
Washington, D.C.  20549-7010

     Re:       Novelis Inc. Supplemental Response Letter
     File No.  1-32312

Dear Mr. Decker,

     I write in response to your letter dated November 15, 2005, in which you
requested certain supplemental information in connection with the Form 8-K that
Novelis Inc. ("Novelis") filed pursuant to Item 4.02 of Form 8-K on November 14,
2005 (the "8-K"). Specifically, you asked when Novelis intends to file its
restated financial statements for the first and second quarter of 2005.

     As noted in the 8-K and the exhibits thereto, (a) Novelis's Audit Committee
has engaged independent outside advisers to assist the company in conducting a
full review of matters relating to reserves and contingencies as well as
adjustments made to arrive at the company's opening balance sheet as of January
6, 2005 and (b) a majority of Novelis's lenders under its Credit Agreement dated
as of January 7, 2005 have consented to the delivery of the required financial
statements under such Credit Agreement on or before February 13, 2006. While
Novelis will not file its restated financial statements for the first and second
quarters or its third quarter financial statements until the independent review
is completed, the company currently expects to file the restated and third
quarter financial statements before February 13, 2006. However, Novelis is not
in a position at this time to definitively state when those financial statements
will be filed.

     Novelis is aware that when filing the restated quarterly reports on Form
10-Q/A for the first and second quarter of 2005 it must:

          •    fully comply with APB 20, paragraphs 36 and 37;
          •    fully update all affected portions of the previously filed Forms
               10-Q, including MD&A;
          •    update Part I, Item 4 of Form 10-Q disclosures on its disclosure
               controls and procedures to include:





                    o    a discussion of the restatement and the facts and
                         circumstances surrounding it,
                    o    how the restatement impacted the CEO and CFO's original
                         conclusions regarding the effectiveness of their
                         disclosure controls and procedures,
                    o    anticipated changes to disclosure controls and
                         procedures and/or internal controls over financial
                         reporting to prevent future misstatements of a similar
                         nature, such disclosure to be prepared by reference to
                         Items 307 and 308(c) of Regulation S-K (noting that
                         Novelis is not yet required to provide its annual
                         report on internal control over financial reporting as
                         it not yet an accelerated filer; the company will first
                         be required to file such report in its Form 10-K for
                         the year ending December 31, 2006); and
          •    update its Section 302 and 906 certifications.

     Novelis also hereby acknowledges that:

          •    the company is responsible for the adequacy and accuracy of the
               disclosure in its filings;
          •    SEC staff comments or changes to disclosure in response to staff
               comments do not foreclose the SEC from taking any action with
               respect to the filing; and
          •    the company may not assert staff comments as a defense in any
               proceeding initiated by the SEC or any person under the federal
               securities laws of the United States.

     Should you have any further questions, please contact our General Counsel,
Les Parrette at 404-814-4282.


Regards,

/s/ Brian W. Sturgell
Brian W. Sturgell
Chief Executive Officer


cc:  Ms. Meagan Caldwell
     Mr. Leslie J. Parrette, Jr.