SecProbe.io

Mail  Stop 4561
November 4, 2015

Robert P. Fishman
Senior Vice President and Chief Financial Officer
NCR Corporation
3097 Satellite Boulevard
Duluth, GA 30096

Re: NCR Corporation
 Form 10 -K for the Fiscal Year Ended December 31, 2014
Filed February 27, 2015
File No. 001 -00395

Dear Mr. Fishman :

We have reviewed your 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 these comments within ten business days by providing the requested
information or advi se us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comments, we may have additional comments.

General

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.

As you know, Sudan and Syria are designated by the Department of State as state sponsors of
terroris m, and are subject to U.S. economic sanctions and export controls.   Please describe to us
the nature and extent of your past, current, and anticipated contacts with Sudan and Syria since
your letter to us, whether through subsidiaries, affiliates, distribu tors, partners, resellers,
customers, joint ventures or other direct or indirect arrangements.   You should describe any
services, products, information or technology you have provided to Sudan or Syria, directly or
indirectly, and any agreements, commercia l arrangements, or other contacts you have had with
the governments of those countries or entities they control.

Robert P. Fishman
NCR Corporation
November  4, 2015
Page 2

 2. Please discuss the materiality of the contacts with Sudan and Syria you describe in response to
the comment above, and whether those contacts 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 sub sequent 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 shar e
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.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Resul ts from Operations, page 23
3. We note you include a supplemental revenue information table in your quarterly earnings
releases on Form s 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.  P lease
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 Regulation S -K and Section III
of SEC Release 33 -8350.

Notes to Consolidated Financial Statements

Note 10. Commitments and Contingencies, page 81

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 reason able possibility that
losses exceeding amounts already recog nized 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 exceedin g amounts already recog nized 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.

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 the information the Securities Exchange Act of 1934 and all
applicable Exchan ge Act rules require.   Since the company and its management are in possession of all

Robert P. Fishman
NCR Corporation
November  4, 2015
Page 3

 facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the
disclosures they have made.

 In responding to our comments, please p rovide a written statement from the company
acknowledging that:

 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
Commissio n 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.

You may contact Frank Knap p, Staff Accountant, at (202) 551 -3805, or Melissa Kindelan,
Staff Accountant, at (202) 551 -3564 , if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202) 551 -3499  with any other questions.

Sincerely,

 /s/  Kathleen Collins

Kathleen Collins
Accounting Branch Chief
Office of Information Technologies and
Services