SecProbe.io

Mail Stop 4561
October 16, 2017

Robert Fishman
Executive 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, 2016
Filed February 24, 2017
File No. 001 -00395

Dear Mr. Fishman :

We have limited our review of your filing to the financial statements and related
disclosures 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 advise us as soon as possible when you wil l 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.

Form 10 -K for the Fiscal Year Ende d December 31, 2016

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

General

1. You state on page 4 that a significant portion of revenue is derived from your growing
service -based business (including your cloud and hos ted businesses) for which backlog
information is  not measured.  In your  slideshow presentation and the earnings call
transcripts, you attribute the growth in cloud revenue to prior period bookings.  Please
revise to include a discussion of bookings in MD&A  or advise.  Refer to Item 303(a) of
Regulation S -K and Section III.B of SEC Release No. 33 -8350.

Robert Fishman
NCR Corporation
October 16, 2017
Page 2

 Revenue and Operating Income by Segment, page 30

2. You state that software revenue increased due to growth in all revenue streams, which
include software li cense, software maintenance, cloud and professional services.  You do
not provide quantification to demonstrate the relative magnitude of each factor in your
MD&A disclosures; however, we note such information is provided in your slide show
presentations.  Similarly, you attribute the flat growth in hardware revenue to growth in
ATM and self -checkout revenue offset by declines in point -of-sale and IPS revenue
without quantifying how each impacted your 2016 revenues.  Please quantify the
individual impact wh en two or more  factors contribute to material changes in the
operating segment revenue.  Refer to Item 303(a)(3)(iii) of Regulation S -K and Section
III.D of SEC Release No. 33 -6835.

Form 8 -K Filed July 20, 2017

3. We note your presentation on non -GAAP gross margin and non -GAAP gross margin rate
for each of your software, services and hardware segments in Exhibit 99.2.  In your future
presentations, please revise to present the most directly comparable GAAP financial
measure and provide a reconciliation to such measure.  Refer to Regulation G.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Frank Knapp, Staff Accountant at (202) 551-3805  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