SecProbe.io

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August 14, 2015

United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549

Attention: Craig D. Wilson, Senior Assistant Chief Accountant

Re:   Unisys Corporation
         Form 10-K for the Fiscal Year Ended December 31, 2014
         Filed February 23, 2015
         Form 10-Q for the Quarterly Period Ended March 31, 2015
         Filed April 30, 2015
         File No. 001-08729

Dear Mr. Wilson:

On behalf of Unisys Corporation (the "Company"), set forth below is the
Company's response to the comment of the Staff of the Securities and Exchange
Commission regarding the above referenced filings set forth in the Staff's
letter dated July 31, 2015.  For your convenience, we have repeated the
comment set forth in the Staff's letter and followed the comment with the
Company's response.

FORM 10-Q FOR THE QUARTERLY PERIOD ENDED MARCH 31, 2015

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

NOTE E.  SEGMENT INFORMATION, PAGE 9

COMMENT 1
We note your response to prior comment 3 and expectation that were a Step 2
goodwill analysis required, the results would indicate no impairment of the
Services segment goodwill recorded at December 31, 2014.  Since a Step 2
analysis of goodwill of the Services segment, if required, would be performed
at the reporting unit level, please document for us the results of each
respective reporting unit's goodwill impairment assessment you performed
pursuant to ASC 350-20-35-3F through 35-3G, with consideration of the factors
in ASC 350-20-35-3C(a) through (g).

RESPONSE TO COMMENT 1
As mentioned in the Company's response to the Staff's prior comment 3, the
changes referred to in Note (e) necessitated a change, as of January 1, 2015,
in the reporting units of the Company's Services segment.  In accordance with
ASC 350-20-35-45, the Company reassigned assets and liabilities to the
affected reporting units.  In addition, goodwill of the Services segment,
approximately $75 million, was reassigned to the affected reporting units
using a relative fair value allocation approach.  The Services segment
reporting units are as follows: Cloud & Infrastructure Services, Application
Services, and Business Processing Outsourcing (BPO) Services.

After the reassignments mentioned above, the Company determined that the
carrying amount of each of its Services segment reporting units did not exceed
their estimated fair value.  Since the carrying amounts of each of the
Services segment reporting units were all negative, the Company then
considered ASC 350-20-35-8A in determining whether it was necessary to
perform a Step 2 impairment analysis.  This consideration included an
evaluation, using the process described in ASC 350-20-35-3F through 35-3G,
including the events and circumstances provided in ASC 350-20-35-3C (a)
through (g).  In some cases, the consideration of events and circumstances
provided in ASC 350-20-35-3C (a) through (g) applied equally to each of the
three Services segment reporting units.

An overview of the Company's consideration of the factors in ASC 350-20-35-3C
follows:

     a) Macroeconomic conditions such as a deterioration in general economic
        conditions, limitations on accessing capital, fluctuations in foreign
        exchange rates, or other developments in equity or credit markets.

        Consideration:  In management's opinion, long-term macroeconomic
        conditions did not deteriorate materially during 2014.  During 2014,
        the Company faced no limitations on accessing capital.  During the
        three years ended December 31, 2014, the Company made payments to
        reduce long-term debt by approximately $389 million through the
        issuance of $210 million of 6.25% senior notes due 2017 and cash on
        hand.  In addition during 2014, the Company extended the term, until
        June 2018, of its previously existing secured revolving credit
        facility which provides for loans and letters of credit up to an
        aggregate amount of $150 million.  At December 31, 2014, the Company
        reported a cash balance of approximately $494 million and debt of
        $224 million.  Foreign currency negatively impacted revenue by
        approximately one-percentage point during 2014.

     b) Industry and market considerations such as a deterioration in the
        environment in which an entity operates, an increased competitive
        environment, a decline in market-dependent multiples or metrics
        (considered in both absolute terms and relative to peers), a change
        in the market for an entity's products or services, or a regulatory
        or political development.

        Consideration:  The Company's Services segment reporting units
        participate in the information technology services industry which was
        and is expected to continue to be highly competitive.  The Company
        Services segment reporting units did not see nor do they expect to
        see a material deterioration in either this environment or a material
        change in the market for their services.  In its fair value
        estimation as of January 1, 2015 used to reallocate goodwill among
        Services segment reporting units, the Company examined industry
        market multiples and these multiples were approximately the same as
        the multiples used during the 2014 goodwill evaluation, as well as
        the preceding evaluation in 2013.  The Company's Services segment
        reporting units were not and are not expected to be materially
        impacted by regulatory or political developments.

     c) Cost factors such as increases in raw materials, labor, or other
        costs that have a negative effect on earnings and cash flows.

        Consideration:  During 2014, the Company was very diligent in
        reducing its cost structure as the combination of selling, general
        and administrative expense and research and development expense
        decreased by approximately 1%.  Interest expense decreased 7% in
        2014.  Overall, the Company has reduced its interest expense from
        $102 million in 2010 to $9 million in 2014. As part of its cost
        savings initiatives, the Company has increased the percentage of its
        workforce operating in lower-cost offshore and onshore delivery
        models from approximately 30% at December 31, 2011 to 36% at
        December 31, 2014.  In addition, the Company continues to plan to
        increase this percentage.

     d) Overall financial performance such as negative or declining cash
        flows or a decline in actual or planned revenue or earnings compared
        with actual and projected results of relevant prior periods.

        Consideration:   For the Company and many of its competitors, 2014
        was a challenging year.  Lower demand for IT services projects
        resulted in a 2014 decline in total Services revenue of 2.3% when
        compared with 2013, with Cloud & Infrastructure Services declining
        3.8%, Application Services declining .6% and BPO Services increasing
        3.2%.  The Services segment operating profit margin in 2014 was 3.4%
        compared with 4.8% in 2013.  The Company also experienced an overall
        decline in net income and cash flows from operating activities.
        However, the Company delivered its sixth consecutive year of
        profitability with 2014 diluted earnings per share of $.89, and
        generated net cash from operating activities of approximately $121
        million (approximately $305 million before defined benefit pension
        plan contributions).  The Company ended 2014 with approximately $494
        million of cash.

     e) Other relevant entity-specific events such as changes in management,
        key personnel, strategy, or customers; contemplation of bankruptcy;
        or litigation.

        Consideration:  On December 16, 2014, in order to guide the Company
        to profitable revenue growth, it was announced that a new President
        and Chief Executive Officer would be joining the Company effective
        January 1, 2015.  No such other events occurred during 2014.

     f) Events affecting a reporting unit such as a change in the composition
        or carrying amount of its net assets, a more-likely-than-not
        expectation of selling or disposing all, or a portion, of a reporting
        unit, the testing for recoverability of a significant asset group
        within a reporting unit, or recognition of a goodwill impairment loss
        in the financial statements of a subsidiary that is a component of a
        reporting unit.

        Consideration:  No such events occurred during 2014.

     g) If applicable, a sustained decrease in share price (considered in
        both absolute terms and relative to peers).

        Consideration:  During 2014, the Company did not experience a
        sustained decrease in its share price.  The Company's common share
        price was $33.57 on December 31, 2013 and $29.48 on December 31,
        2014.

The Company also took into consideration whether in any of its Services
segment reporting units there were significant differences between the
carrying amount and the estimated fair value of its assets and liabilities,
or the existence of significant unrecognized intangible assets and found none
to be in existence.

Application of the goodwill impairment analysis requires significant
judgment.  Based on consideration of the weight of evidence of the factors
considered above, the Company concluded that it was not more likely than not
that any of the Services segment reporting units goodwill was impaired as of
December 31, 2014.

                                 *   *   *

In addition, the Company acknowledges that:
* the Company is responsible for the adequacy and accuracy of the disclosure
  in the filings;
* staff comments or changes to disclosure in response to staff comments do
  not foreclose the Commission from taking any action with respect to the
  filings; 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.

The Company hopes that the above is responsive to the Staff's comments.

Very truly yours,

UNISYS CORPORATION

/s/ Janet Brutschea Haugen

Janet Brutschea Haugen
Senior Vice President and Chief Financial Officer
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