SecProbe.io

July 23, 2010

Mr. Merrill A. Miller, Jr. Chief Executive Officer National Oilwell Varco, Inc. 7909 Parkwood Drive Houston, TX 77036
Re: National Oilwell Varco, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2009 Filed February 26, 2010 Proxy Statement on Schedule 14A Filed April 1, 2010 Response Letter Dated June 8, 2010 File No. 1-12317
 Dear Mr. Miller:
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 this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
 General

 1. We note your response to our prior comments 1 and 2 in which you clarify that your “one
customer” is actually a shipyard.  Revise your disclosure to clarify this situation as put
forth in your responses.  Identify the shipyard or  tell us why that is e ither not required or
would cause you competitive harm.
 2. We note your response to comment 1 from our  letter dated May 25, 2010 with respect to
information regarding potential liability in th e event that your employees or any of your
products are involved in an even t that leads to property dama ge, personal injury, death or
the discharge of hazardous materials into the environment.  Please describe to us in more detail your insurance coverage with respect to any liability related to any such event.
Your response should describe  the types of claims covere d, and the applicable policy

Mr. Merrill A. Miller, Jr. National Oilwell Varco, Inc. July 23, 2010 Page 2
limits and deductibles and should address, w ithout limitation, your insurance coverage
with respect to any liability related to any resulting negative envir onmental effects.  In
addition, please describe to us the allocation of liability  and related indemnification
obligations set forth in y our customer contracts.
 Definitive Proxy Statement on Schedule 14A filed on April 1, 2010

Annual Incentive Award, page 30

3. We note your response to comment 7 from our  letter dated May 25, 2010.  Please confirm
that, in future filings, you will include the hi storical information you provided in the first
full paragraph on page 6 of your response letter.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure 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 federa l securities laws of  the United States.

Please contact Douglas Brown at  (202) 551-3265, or, in his ab sence, Laura Nicholson at
(202) 551-3584 with any other questions.

Sincerely,

H. Roger Schwall Assistant Director