SecProbe.io

July 22, 2014

Via E -mail
Ms. Janet Brutschea Haugen
Senior Vice President and Chief Financial Officer
Unisys Corporation
801 Lakeview Drive, Suite 100
Blue Bell, PA 19422

Re: Unisys Corporation
 Form 10-K for the Fiscal Year Ended December 31, 2013
Filed February 24, 2014
File No. 001 -08729

Dear Ms. Haugen :

We have reviewed your filing an d have the following comments.  Please note that we
have limited our review to only your financial statements and related disclosures.  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 advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstance s or do not
believe an amendment is appropriate, please tell us why in your response.

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

Item 8. Fina ncial Statements and Supplementary Data (Incorporated by reference from the
Unisys 2013 Annual Report to Stockholders, Exhibit 13)

Notes to Consolidated Financial Statements

Note 1. Summary of Significant Accounting Policies

Revenue recognition, page 2 1

1. We note your disclosure on pages 7 and 8 regarding system development activity and
customer prepayments.  Please tell us whether the customer prepayments relate to only
system development services or if there are other services being provided.  Please te ll us
whether these services have standalone value and tell us how you determined that the

Ms. Janet Brutschea Haugen
Unisys Corporation
July 22, 2014
Page 2

 customer prepayments should be recognized over the initial contract term.  Please refer to
the authoritative guidance you relied upon when determining your accountin g.

Note 4. Goodwill, page 25

2. We note your disclosure that you performed your annual impairment test in the fourth
quarter and that goodwill was not impaired.  If you performed a Step 2 quantitative
goodwill analysis, p lease tell us the percentage by whic h the fair value of each reporting
unit exceeded its carrying value.  To the extent that a reporting unit’s estimated fair value
is not substantially in excess of the carrying value and is potentially at risk of failing step
one of your goodwill impairment  analysis, please disclose  in future filings, the percentage
by which the fair value exceeded the carrying value as of the date of the most recent test.
If you did not perform a Step 2 quantitative analysis, please tell us how you considered
ASC 350 -20-35-8A.

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 Exchange 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.

 In responding to our comments, please provide  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 Commission 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 Knapp, Staff Accountant  at (202) 5 51-3805 or Christine Davis,
Assistant Chief Accountant at (202) 551 -3408  if you have questions regarding comments on the
financial statements and re lated matters.  Please contact me at (202) 551 -3406  with any other
questions.

Sincerely,

 /s/ Patrick Gilmore

Patrick Gilmore
Accounting Branch Chief