SecProbe.io

April 4, 2013

Via Email
Jennifer M. Daniels
Senior Vice President, General Counsel  & Secretary
NCR Corporation
3097 Satellite Boulevard
Duluth, GA 30096

Re: NCR Corporation
  Registration Statement on Form S-4
Filed  March 26, 2013
  File No.  333-187540

Dear Ms. Daniels :

We have limited our review of your registration statement to those issues we have
addressed in our 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 by amending your registration statement and providing the
requested information .  Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments , we may have  additional comments.

General

1. Please tell us why you have not registered the guarantees of the exchange notes by your
two subsidiaries, NCR International, Inc. and Radiant Systems, Inc.   Given that the
subsidiary guarantors will jointly an d severally and unconditionally guarantee the
exchange notes, the guarantees appear to be separate securities that need to be registered.
Provide appropriate disclosure on the prospectus cover page regarding the guarantees and
have each subsidiary guarant or sign the registration statement, or advise us why you
believe that these guarantees are not required to be registered in this filing.

Exhibit 5.1

2. We note that the legal opinions do not express an opinion as to whether the guarantees
will constitute v alid and binding obligations of the guarantees.  Please provide an opinion
of counsel as to whether each of the guarantees will be binding obligations of the
applicable guarantor .  See Item 601(b)(5) of Regulation S -K.

Jennifer M. Daniels
NCR Corporation
 April 4, 2013
Page 2

 We urge all persons who are responsi ble for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request accelera tion of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant t o delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effect iveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rule  461 regarding requests for  acceleration .  We will consider a written
request for acceler ation of the effective date of the registration statement as confirmation of the
fact that those requesting acceleration are aware of their respective responsibilities under the
Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

You may contact Jan Woo, Attorney -Advisor,  at (202) 551 -3453 if you have any
questions.  If you need further assistance, please contact me at  (202) 551 -3462 or Barbara C.
Jacobs, Assistant Director, at (202) 551 -551-3730.

Sincerely,

 /s/ Mark P. Shuman

Mark P. Shuman
Branch Chief – Legal

cc: Via Email
 Richard Aftanas, Esq.
 Skadden, Arps, Slate Meagher & Flom LLP