SecProbe.io

June 9, 2011
 Via E-Mail

Clay C. Williams Executive Vice President and  Chief Financial Officer National Oilwell Varco, Inc. 7909 Park Circle Drive Houston, Texas 77036-6565
Re: National Oilwell Varco, Inc.
Form 10-K for Fiscal Year Ended December 31, 2010 Filed February 23, 2011
  File No. 001-12317

Dear Mr. Williams:
We have reviewed your letter dated May 23, 2011 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 te n business days, 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 circum stances, please tell us w hy in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.
            Form 10-K for Fiscal Year Ended December 31, 2010

General
 1. We note your response to prior comment one  in your May 23, 2011 letter.  Please
describe the products or services that you ha ve provided and those which you continue to
provide, directly or indirectl y, through subsidiaries or othe r arrangements, to Iran, Syria
and Cuba.  Describe in your response the sales you reference in your response to prior
comment two in which your customer may ha ve shipped or used goods in Cuba.  Please
clarify whether any of your c ontacts involved the governments of Iran, Syria or Sudan or
entities controlled by these governments, incl uding whether any such entities were co-
parties on projects or to agreements.
 2. We note the information in your response to prior comment two in your May 23, 2011
letter regarding the percentage  of direct sales to Iran, Syria, Sudan and Cuba from

Clay C. Williams
National Oilwell Varco, Inc. June 9, 2011 Page 2

 January 1, 2008 to December 31, 2010.  Please pr ovide the approximate dollar amount of
revenue from all sales, direct and indire ct, to these countries  during each of the
referenced fiscal years.  Please also provi de the approximate dolla r amount of revenue
from sales to these countries during the subsequent interim period.
 Financial Statements

 Notes to Consolidated Financial Statements

 Note 12 – Commitments and Contingencies, page 85

 3. We note your response to our prior comme nt six in your May 23, 2011 letter.  As
requested in our prior comment, please describe  any matters for which you have recorded
a contingent liability pursuant to FASB ASC 450-20-25.  In addition, with regard to any
contingencies for which there is a reasonable possibility of a loss, please disclose an
estimate of the amount of the reasonably possi ble loss or range of loss for which you have
not recognized a liabil ity.  In connection with your respons e, please provide us with your
proposed disclosure.

You may contact Andri Boerman at (202) 551- 3645 or me at (202) 551-3311 if you have
questions regarding comments.

Sincerely,
   /s/ Ethan Horowitz   Ethan Horowitz  Accounting Branch Chief