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CORRESPONDENCE

 NEC Corporation

7-1, Shiba 5-chome, Minato-ku, Tokyo 108-8001, Japan

Tel. +81-3-3454-1111

 May 14, 2020

 VIA
EDGAR AND FEDEX

Re:
 NEC Corporation

Registration Statement on Form 20-F

Filed May 14, 2020

 CIK
No. 0000072127

 Michael C. Foland, Esq.

Division of Corporation Finance

 Securities and Exchange
Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Dear Mr. Foland:

 NEC Corporation
(“we”, “NEC” or the “Company”) hereby transmits via EDGAR for filing with the Securities and Exchange Commission (the “SEC”) a Registration Statement on Form 20-F (the
“Revised Registration Statement”), relating to the registration of NEC’s common stock under Section 12 of the U.S. Securities Exchange Act of 1934, as amended (the “Exchange Act”). The Company previously filed a
Registration Statement on Form 20-F (File No. 000-12713) (the “Initial Registration Statement”) on March 17, 2020 and subsequently filed a request
for withdrawal of the Initial Registration Statement on May 12, 2020 to prevent the Initial Registration Statement from becoming effective prior to the completion of the review by the staff of the Division of Corporation Finance (the
“Staff”). The Revised Registration Statement contains revisions in order to address comments regarding the Initial Registration Statement that were previously provided by the Staff. Marked redline copies, which show changes from the
Initial Registration Statement, are being furnished supplementally via FedEx for the convenience of the Staff.

 In addition, we are
providing the following responses to your comment letter, dated April 9, 2020, regarding the Initial Registration Statement. To assist your review, we have retyped the text of the Staff’s comments in bold, italicized text below.

Securities and Exchange Commission

 2

May 14, 2020

 Form 20-F filed March 17, 2020

Forward-Looking Statements, page 1

1.
 Please note that the safe harbor provided by the Private Securities Litigation Reform Act of 1995 is not
available for statements contained in an initial Exchange Act registration statement. Please remove your reference to the safe harbor.

Response:

 We respectfully acknowledge
the Staff’s comment and have revised the disclosure in the Revised Registration Statement to remove the reference to the safe harbor. Please see “Forward-Looking Statements.”

Item 3. Key information

 Selected Financial Data, page
4

2.
 Please revise the weighted average number of common shares outstanding in fiscal 2016 to reflect the
effects of the ten-for-one share consolidation on October 1, 2017. Refer to paragraphs 26—28 of IAS 33.

Response:

 We respectfully acknowledge
the Staff’s comment and have revised the weighted average number of common shares outstanding as of March 31, 2016 to reflect the effects of the ten-for-one
share consolidation on October 1, 2017. Please see “Item 3.A. Key Information—Selected Financial Data.”

Securities and Exchange Commission

 3

May 14, 2020

 Item 3. Risk Factors

We conduct a substantial amount of business with a concentrated customer base, page 12

3.
 Disclose the reasons why you temporarily became ineligible to participate in the bidding process for
projects with a significant number of Japanese government agencies and local governments in 2016 and 2017.

 Response:

 We respectfully acknowledge the Staff’s comment and have revised the disclosure in the Revised Registration Statement to expand
on the background for our becoming temporarily ineligible to participate in public bidding processes with certain government entities. Please see “Item 3.D. Key Information—Risk Factors—Risks Related to Our Business Operations—We
conduct a substantial amount of business with a concentrated customer base, and our business could suffer if they encounter business problems or decide to reduce their business with us.”

Item 4. Information on the Company

 Medium-Term
Management Plan, page 28

4.
 Please describe any reasonably known trends or uncertainties that you have experienced, or may
experience, in implementing your Medium-Term Management Plan due to COVID-19, specifically any material resource constraints in implementing this plan.

Response:

 Based on our current
assessment of the actual and potential impact of COVID-19 on our business mostly based on information related to developments after the date of the filing of the Initial Registration Statement, we believe that
the primary impact of the pandemic on our ability to implement our Medium-Term Management Plan is the potential decline in IT-related investments by our customers. Although we have not yet observed significant
declines, the severity of impact of any such declines on our financial performance for the fiscal year ending March 31, 2021 and beyond would depend among other things on the length of time until the pandemic is eventually resolved and the
severity of the impact of the pandemic on the Japanese and global economy. With respect to resource constraints, we have not yet experienced significant disruptions in our supply chain. However, we believe that the ongoing pandemic could result in
facility closures, general business shutdowns and financial difficulties on the part of our suppliers, which may impact our ordinary course procurement processes. In line with the foregoing, we have revised the disclosure in the Revised Registration
Statement to discuss COVID-19. Please see “Item 3.D. Key Information—Risk Factors—Risks Related to Our Operating Environment—The recent outbreak of the novel coronavirus could have a
significant negative impact on our business, results of operations and financial condition,” “Item 4.B. Information on the Company—Business Overview—Overview—Medium-Term Management Plan—Impact of the Coronavirus
Pandemic” and “Item 5. Operating and Financial Review and Prospects—Introduction—Recent Developments—Coronavirus.”

Securities and Exchange Commission

 4

May 14, 2020

 Item 5. Operating and Financial Review and Prospects

Introduction, page 37

5.
 We note that you revised your segment structure during fiscal 2019 and then again in fiscal 2020. Please
include a comprehensive discussion of the reasons for each of these changes. In this regard, explain further the changes to your internal organization during fiscal 2019, why such changes were made and how they impacted the composition of your
operating segments. In addition, clarify what lead to additional changes in your internal organization in fiscal 2020 and how those changes further impacted your operating segments.

Response:

 We respectfully acknowledge
the Staff’s comment and have revised the disclosure in the Revised Registration Statement to disclose the reasons and other background information regarding the segment reorganizations that took effect on April 1, 2018 (the “2018
Segment Reorganization”) and April 1, 2019 (the “2019 Segment Reorganization”).

 The 2018 Segment Reorganization was
implemented in order to consolidate our business divisions that are primarily tasked with expanding in global markets into a single business segment in order to enhance our ability to manage these businesses as a whole in line with our new key
business initiative of expanding our overseas businesses. The businesses that were incorporated into our Global business segment included our global software and service business for service providers, our wireless solutions business and our
submarine systems business from the Telecom Carrier business segment as well as our global unified communications business and display solutions business from our System Platform business segment. Accompanying these transfers, we renamed our former
Telecom Carrier business segment as the Network Services business segment.

 The 2019 Segment Reorganization was implemented in order to
move certain businesses to other business segments where operations had become more related and mutually complementary over time due to the evolving nature of the technology industry. As part of the 2019 Segment Reorganization, (i) our
enterprise network solutions business was moved from our System Platform business segment to our Network Services business segment, (ii) our global unified communications business was moved from our Global business segment to our System
Platform business segment and (iii) our security business was moved from our System Platform business segment to our other business activities.

In addition to the 2018 Segment Reorganization and the 2019 Segment Reorganization, from the beginning of the fiscal year ended March 31,
2020, we have added a new segment profit (loss) line item in our segment information, which is measured by deducting amortization expenses on intangible assets recognized as a result of mergers and acquisitions as well as M&A-related expenses (financial advisory fees, etc.) from selling, general and administrative expenses and other operating expenses for the respective segment, as an indicator for measuring underlying
profitability in order to clarify the contribution of acquired companies to our overall earnings.

 We also note that, in lieu of
quantifying the effects of these segment reorganizations, all of the segment information presented throughout the registration statement reflects these segment organizational changes as though the changes occurred prior to the beginning of the
relevant period to make period-to-period comparisons easier for the reader. Please see “Item 5. Operating and Financial Review and
Prospects—Introduction—Segment Reorganizations.”

Securities and Exchange Commission

 5

May 14, 2020

 Key Components of Results of Operations, page 39

6.
 For each of the material business segments that you describe, please disclose that segment´s
reliance on a single or few customers. In this regard, you state on page 12 that a substantial portion of your revenues are generated by government entities and NTT group. Additionally, to the extent that your business is substantially dependent on
a contractual arrangement with a significant customer, please identify that customer and file the contract as an exhibit to your amended registration statement.

Response:

 We respectfully acknowledge
the Staff’s comment and have revised the disclosure to discuss customer concentration within our business segments. See “Item 5. Operating and Financial Review and Prospects—Introduction—Key Components of Results of
Operations—Revenue.”

7.
 Please describe how COVID-19 is reasonably expected to affect
your financial condition, key performance metrics and results of operations. In this regard, while we note that during the nine months ended December 31, 2019, revenue increased 6.9%, if it is reasonably likely that your revenues will decline
or otherwise be materially adversely affected by the COVID-19 pandemic for the year ended March 31, 2020, you must describe these material adverse effects. Please refer to CF Disclosure Guidance: Topic
No. 9 (March 25, 2020) for additional guidance.

 Response:

As mentioned in our response to Question 4 above, we have revised the disclosure to discuss the impact of
COVID-19 on the Company based primarily on information related to developments after the date of the filing of the Initial Registration Statement. Please see “Item 3.D. Key Information—Risk
Factors—Risks Related to Our Operating Environment—The recent outbreak of the novel coronavirus could have a significant negative impact on our business, results of operations and financial condition,” “Item 4.B. Information on
the Company—Business Overview—Overview—Medium-Term Management Plan—Impact of the Coronavirus Pandemic” and “Item 5. Operating and Financial Review and Prospects—Introduction—Recent
Developments—Coronavirus.”

 As for the effect of COVID-19 on our financial results for
the fiscal year ended March 31, 2020, we believe that our revenue and operating income for the fourth quarter of such fiscal year will exceed the expectations that we had at the beginning of such fiscal year, as the adverse effects of COVID-19 on the Japanese economy and financial markets prior to such fiscal year end were still relatively benign.

Securities and Exchange Commission

 6

May 14, 2020

 Item 5. Operating and Financial Review and Prospects

Recent Developments, page 44

8.
 Please describe if, and how, remote work arrangements have adversely affected your ability to maintain
operations, including financial reporting systems, internal control over financial reporting and disclosure controls and procedures. In this regard we note your initiative to promote telework and staggered work hours
(https://www.nippon.com/en/news/yjj2020021800235/nec-promoting-teleworking-to-avoid-virus-infections.html). Please describe any
challenges you anticipate to maintain controls if these arrangements continue for an extended period of time.

 Response:

 Regarding our remote work arrangements, because we had previously introduced a policy of allowing employees to work from home in 2018,
we have been able to take advantage of existing infrastructure in order to implement the pandemic-related transition. In order to further adapt to these remote working arrangements in response to COVID-19, we
have converted to various electronic means of internal authorizations and execution of agreements and work orders. Although these remote work arrangements present new challenges for monitoring the operations of our businesses, we expect that our
financial reporting systems, internal controls over financial reporting and disclosure controls and policies will continue to function effectively, even in the event that remote work arrangements continue for an extended period of time. We have
revised the disclosure to reflect the above information. Please see “Item 3.D. Key Information—Risk Factors—Risks Related to Our Operating Environment—The recent outbreak of the novel coronavirus could have a significant negative
impact on our business, results of operations and financial condition” and “Item 5. Operating and Financial Review and Prospects—Introduction—Recent Developments—Coronavirus.”

Securities and Exchange Commission

 7

May 14, 2020

 Segment Analysis, page 51

9.
 You state that while Public Infrastructure revenues benefited from higher sales from large-scale projects
in the aerospace and defense sector, this was substantially offset by the decrease in sales of mobile and industrial equipment by JAE. As another example, you indicate that while Enterprise segment profit increased from the system implementation
service business, such profit was negatively impacted by larger expenses for research and development and business structure improvement costs. Where two or more factors contribute to a material change in reported amounts, including any offsetting
factors, the contribution of each identified factor should be described in quantified terms. Please revise your disclosures throughout your operating results discussion accordingly. Refer to Item 5.A.1 of Form
20-F and Section III.D of SEC Release No. 33-6835.

Response:

 We respectfully acknowledge
the Staff’s comment and have considered Item 5.A.1 of Form 20-F and the guidance within Section III.D of SEC Release No. 33-6835. We have made revisions
throughout the operating results section in the Revised Registration Statement to disclose the contribution of each identified factor in quantified terms to the extent reasonably practicable. We respectfully note to the Staff that, while we have
made revisions to enhance the quantification provided with respect to our results, such quantification at a more detailed level is not always reasonably practicable, particularly with regard to sub-businesses
for which we do not present separate results. In such instances, we have endeavored to narratively describe the relative contribution of the applicable factors qualitatively.

Note 3. Significant Accounting Policies

 Revenue, page
F-20

10.
 You stat