SecProbe.io

June 10, 2010
 Robert Fishman Senior Vice President and  Chief Financial Officer
NCR Corporatio n
3097 Satellite Boulevard
Duluth, GA 30096
Re: NCR Corporation
 Form 10-K for the Fiscal Ended December 31, 2009
Filed February 26, 2010
 File No. 001-00395

Dear Mr. Fishman:
 We have reviewed your response letter date d April 12, 2010 in connection with the above
referenced 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for the Fiscal Year Ended December 31, 2009

 Item 8. Financial Statements and Supplementary Data

 Consolidated Statements of Operations, page 42

1. We note your response to prior comment 1.  In your response you indicate that
classification of environmental remediation costs as nonoperating expense is more useful
and informative to investors than cla ssification as discontinued operations.
Notwithstanding the fact that  the operations which gave rise to the environmental
remediation costs were discontinued decad es ago, it appears to the Staff that
classification as discontinued operations is required by SAB Topic 5Z(5).  Please revise
your classification accordingly in future filings.

   Robert Fishman NCR Corporation June 10, 2010 Page 2

Notes to Consolidated Financial Statements

 Note 11 Commitments and Contingencies

 Environmental Matters, page 76

2. We note your response to prior comment 4 where you discuss how you estimated the
amount of the liability allocable to NCR.  We  further note from disclosure on page 35 of
your Form 10-K for the Fiscal Year E nded December 31, 2008 that you established a
range of the share that you and API will join tly bear of the total liability and that you
determined your liability based on the low end of the range.  However, we were unable to locate quantitative disclosures relating to the range.  Given the apparent uncertainty
regarding your allocation assumptions, tell us  why you believe disclo sure regarding your
assumptions, and the possible impact of any ch ange therein, in periods prior to the court
ruling was adequate.  Considering the magnit ude of the adjustment to your liability
subsequent to the court ruling, it appears that  quantification of the range would have been
necessary for a complete understanding of your  potential environmental liability.  Also
tell us how much of the liability you assume d would be allocable to PRP’s, other than
you and API, in periods prior to the court ru ling.  Refer to Question 2 of SAB Topic 5Y
and Section III.B.3 of SEC Release 33-8350.

Item 15.  Exhibits, Financial Statement Schedules, page 93

3. We note your response to prior comment 5.  Please supplementally provide us with a
copy of the letter agreement with Mr. Dors man so that we may better evaluate your
response.

You may contact David Edga r at (202) 551-3459 if you ha ve questions regarding
comments on the financial statements and relate d matters.  Please contact Matthew Crispino at
(202) 551-3456 with any other questions.
Sincerely,

Patrick Gilmore Accounting Branch Chief