SecProbe.io

Mail Stop 4561         J u n e  3 0 ,  2 0 0 9   Anthony Massetti  Senior Vice President and Chief Financial Officer NCR Corporation 1700 South Patterson Blvd.  Dayton, Ohio 45479
Re: NCR Corporation
 Form 10-K for the Year Ended December 31, 2008
Filed February 26, 2009
 File No. 001-00395

Dear Mr. Massetti:

We have reviewed the above-referenced f ilings and have the following comments.
Please note that we have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your document.  If indicated, we think you should revise your document in response to these comments.
If you disagree, we will consider your explanation as to why our comment is inapplicable
or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.
 Please understand that the purpose of our re view 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 Year Ended December 31, 2008

General
1. You disclose on page 25 of the 10-K th at you operate in the Middle East and
Africa and that you derive revenues from  the Caribbean and Latin America,
regions that are generally understood to include Cuba, Iran, Sudan, and Syria.  We
note also that drawdown menus on your website allow nationals of Cuba, Iran, Sudan, and Syria to make business inquiries of you.  In addition, we are aware of

Anthony Massetti
NCR Corporation
June 30, 2009 Page 2
a March 2006 news report indicating that  you collaborated with Ahli United Bank
B.S.C. to deploy your ATM fraud prev ention technology on the bank’s ATMs.
We also are aware that Future Bank B.S. C. describes itself on its website as a
joint venture between Ahli United Bank B.S.C., Bank Melli Iran, and Bank Saderat Iran; and that Future Bank, Bank Melli, and Bank Saderat are included on
the Specially Designated Nationals List ma intained by the Treasury Department.
2. Cuba, Iran, Sudan, and Syria are identifie d by the State Department as state
sponsors of terrorism, and are subject to  U.S. economic sanctions and export
controls.  We note that your Form 10-K  does not include disclosure regarding
contacts with Cuba, Iran, Sudan, or Syria.  Please describe to us the nature and
extent of your past, current, and anticipated contacts with the referenced countries, if any, whether through subsidia ries or other dire ct or indirect
arrangements.  In this regard, address whether, to the best of your knowledge, understanding, or belief, Ahli United Bank employs your products, equipment, components, technology, software, or serv ices in activities in the referenced
countries.  Your response should descri be any products, equipment, components,
technology, software, or servic es you have provided to these countries, directly or
indirectly, and any agreements, commerci al arrangements, or other contacts you
have had with the governments of those c ountries or entities controlled by those
governments.

* * * * * * *

Please 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.  If you amend your
filing(s), you may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cover letter that keys your response to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your response to our comments.
 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:

Anthony Massetti
NCR Corporation June 30, 2009 Page 3
• 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.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 You may contact David Edga r, Staff Accountant, at (202) 551-3459 or me at
(202) 551-3406 if you have any questions  regarding the above comments.
        S i n c e r e l y ,           P a t r i c k  G i l m o r e
Accounting Branch Chief