SecProbe.io

September 10, 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 Response Letter Dated August 5, 2010 File No. 1-12317
 Dear Mr. Miller:
We have reviewed your filing and response le tter, and have the following comments.  In
some of our comments, we may ask you to provi de 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 comment 1 from our  letter dated July 23, 2010, and reissue the
comment.  Please revise your disc losure to clarify your relati onship with the shipyard as
described in your response dated June 8, 2010.  In addition, please identify the shipyard.
In that regard, we note your disclosure at page 22 of your annual report that you had
revenues of 16.6% of total revenue from this customer for the year ended December 31,
2009, and that the loss of this customer or a significant reduction in its purchases could
adversely affect your future revenues or ear nings.  See Item 101(c)(vii) of Regulation S-
K.
2. We note your response to comment 2 from our letter dated July 23, 2010.  Please provide
the information requested in our prior comment 2 with respect to the applicable policy limits and deductibles, and briefly describe th e exclusions referenced  in your response.

Mr. Merrill A. Miller, Jr. National Oilwell Varco, Inc. September 10, 2010 Page 2   We urge all persons who are responsible for the 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 questions.
Sincerely,

H. Roger Schwall Assistant Director