SecProbe.io

July 3 1, 2015

Via E -mail
Scott K. Duff
Interim Chief Financial Officer
National Oilwell Varco, Inc.
7909 Parkwood Circle Drive
Houston, Texas  77036

Re: National Oilwell Varco, Inc.
 Form 10-K for the Fiscal Year Ended
December 31, 2014
Filed February 17, 2015
File No. 1-12317

Dear Mr. Duff :

We have limited our review  of your filing  to the financial statements and related
disclosures 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Form 10 -K for  Fiscal Year Ended December 31, 2014

Business, page 1

Backlog, page 16
1. We note your disclosure of contract backlog.  Tell us how you considered disclosing the
amount or percentage of backlog not reasonably expected to be filled within the current
fiscal year as required by Item 101(c)( 1)(viii) of Regulation S -K.

Scott K. Duff
National Oilwell Varco, Inc
July 31 , 2015
Page 2

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
32

Critical accounting Policies and Estimates, page 47

Goodwill and Other Indefinite -Lived Intangible Assets, page 48

2. We note your disclosure that you performed your annual impairment test in the fourth
quarter and that goodwill was not impaired.  Confirm to us, if true, that no reporting units
are at risk of failing step one in the goodwill impairment test under ASC 350 -20-35-4
through 8.  Otherwise, for reporting units with material goodwill that are at risk of failing
step one in the goodwill impa irment test, disclose the following:

 The percentage by which fair value exceeded carrying value as of the date of the
most recent test;
 A description of how the main valuation assumptions were determined;
 A discussion of the degree of uncertainty associated with the main assumptions.
The discussion regarding uncertainty should provide specifics to the extent
possible; and
 A de scription of potential events and/or changes in circumstances that could
reasonably be expected to negatively affect the main  assumptions .

Refer to Item 303(a)(3)(ii) of Regulation S -K and Section V of Release 33 -8350.

We urge all persons who are respons ible 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 posses sion 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 comp any 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.

Scott K. Duff
National Oilwell Varco, Inc
July 31 , 2015
Page 3

 You may contact Diane Fritz, Staff Accountant , at (202) 551 -3331  or me at (202 ) 551-
3489  with any questions.

Sincerely,

 /s/ Brad Skinner

Brad Skinner
Senior Assistant Chief Accountant