1.	In your letter to us dated September 25, 2012, you discussed contacts with Sudan and Syria. You state on page 33 of the 10-K that in 2014 your branch in Syria maintained a bank account at the Commercial Bank of Syria, which is designated as a Specially Designated National. You disclose on pages 23 and 92 of the 10-K revenues in Africa and the Middle East, regions that include Sudan and Syria.

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•	the sale or transfer of assets, including but not limited to real and personal property;

•	the resolution of employee contracts, benefits and severance obligations;

•	the execution of filings as required with Syrian authorities to deregister in Syria, including the filing of tax audit reports and other necessary submissions;

•	the engagement of third party service providers, such as accountants and legal counsel to effectuate these filings and other actions;

•	the termination, novation or other appropriate action to resolve outstanding third party vendor and customer contracts;

•	the closure of bank accounts that have been maintained in non-blocked banks; and

•	the closure of bank accounts that have been maintained in blocked banks (including the Commercial Bank of Syria).

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2.

Please discuss the materiality of the contacts with Sudan and Syria you describe in response to the comment above, and whether those contracts constitute a material investment risk for your security holders. You should address materiality in quantitative terms, including the approximate dollar amounts of any associated revenues, assets, and liabilities for the last three fiscal years and the subsequent interim period. Also, address materiality in terms of qualitative factors that a reasonable investor would deem important in making an investment decision, including the potential impact of corporate activities upon a company’s reputation and share value. Various state and municipal governments, universities, and other investors have proposed or adopted divestment or similar initiatives regarding investment in companies that do business with U.S.-designated state sponsors of terrorism. You should address the potential impact of the investor sentiment evidenced by such actions directed toward companies that have operations associated with Sudan and Syria.

•	The revenue associated with Syria and Sudan for fiscal 2012 was less than 0.1% of total NCR revenue, and for fiscal 2013, for fiscal 2014 and for the nine months ended September 30, 2015 was 0% of total NCR revenue.

•	We have engaged in no business in Sudan since 2010, and, as disclosed in our September 25, 2012 letter to the Staff, our business in Sudan prior to 2010 was limited in nature.

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Since July 2012, when we suspended operations in Syria, our contacts with Syria have consisted solely of activities related to the wind-down of operations consistent with the terms of wind-down licenses issued by OFAC. We also note that since July 2012, our ongoing public disclosures have made clear for the benefit of our investors that we have suspended operations in Syria. We do not, at this time, anticipate pursuing future business in Syria.

•	State governments, municipalities, and/or universities, together hold, of record, less than 5% of the Company's outstanding shares of common stock.

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•	We are aware of no divestment or related initiatives being directed at NCR by any state governments, municipalities, universities or other investors, and have received no notices or inquiries with respect to any such initiatives. We believe the de minimis nature of the company's former business in these    countries makes it unlikely that such investors would propose divestment.

•	Our past business contacts in Syria, which were comprised of sales of ATMs, related software and peripherals and similar equipment (parts, supplies and services) sold to banks and other customers for use by consumers in their day-to-day life, are not, we believe, of a nature that would engender negative investor sentiment.

3.

We note you include a supplemental revenue information table in your quarterly earnings releases on Forms 8-K that presents revenue on a comparative basis by specific type of offering: cloud, software license/software maintenance, professional services, hardware, and other services. We also note you discuss the results by offering on your earnings calls. Please tell us how you considered including this information here and in your respective Form 10-Q filings as it appears management uses this information to manage the business, and it may be meaningful to investors in understanding known trends and demands as it relates to your product and service offerings. We refer you to Item 303(a) of Registration S-K and Section III of SEC 33-8350.

•	We manage and assess our performance by our four operating segments - Financial Services, Retail Solutions, Hospitality and Emerging Industries - and we provide revenue guidance in total and by operating segment. We do not manage our business or assess our performance by the supplemental revenue streams.

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In accordance with Rule 5-03 of Regulation S-X, we report product revenue and services revenue separately in the Statement of Operations. Product revenue includes hardware, software license and consumables revenue. Services revenue includes software and hardware maintenance (i.e. support services), professional services, installation services and cloud revenue. However, the software-related revenue we provide in our earnings releases includes software license, software maintenance, professional services and cloud revenue - i.e., elements both from our product revenue and from our services revenue and does not, therefore, correspond directly to the reported revenue in our Statement of Operations.

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4.

You state that any costs that may be incurred in excess of those amounts provided as of December 31, 2014 cannot be reasonably determined, or are not currently considered probable. It is not clear from this disclosure whether you believe there is a reasonable possibility that losses exceeding amounts already recognized may have been incurred. Please confirm that in future filings you will revise and clarify your disclosure to state whether you believe there is a reasonable possibility that losses exceeding amounts already recognized may have been incurred and if so, disclose the estimated additional loss or range of loss, or state that such an estimate cannot be made. Please provide us with proposed draft disclosure in your response. We refer you to paragraphs 3 through 5 of ASC 450-20-50.

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•	The Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•	Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission 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 Commission or any person under the federal securities laws of the United States.