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    National Oilwell Varco, Inc.

    7909 Parkwood Circle Drive

    Houston, TX 77036

    PHONE 713-346-7500

August 5, 2010

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Attn: Mr. Douglas Brown

    RE:

    National Oilwell Varco, Inc. (the “Company”)

    Form 10-K for Fiscal Year Ended December 31, 2009

    Filed February 26, 2010 (“2009 Form 10-K”)

    Proxy Statement on Schedule 14A

    Filed April 1, 2010 (“2010 Proxy Statement”)

    Response Letter Dated June 8, 2010 (“Initial Response Letter”)

    File No. 1-12317

Ladies and Gentlemen:

This letter responds to the comments that the Company received from the Staff of the Division of
Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”
or the “SEC”) by letter dated July 23, 2010. For your convenience, the Company’s responses are
prefaced by the Commission’s comment in bold text. All capitalized terms used herein and not
defined herein shall have the meanings given to them in our 2009 Form 10-K or our 2010 Proxy
Statement.

Form 10-K for the Fiscal Year Ended December 31, 2009

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
either not required or would cause you competitive harm.

Response: We do not believe that disclosure of the shipyard is required under Item 101 of
Regulation S-K. As noted in our Initial Response Letter, none of the contracts, on an individual
basis, are material to the company. We also noted that our contracting with the shipyard, rather
than our direct customers, is a function of the general contractor arrangements. Since disclosure
of the direct customers (i.e., the true purchasers) would not be required under Item 101 of

U. S. Securities and Exchange Commission

August 5, 2010

Page 2 of 3

Regulation S-K if the general contractor shipyard were removed from the middle of these contracting
arrangements, we do not believe disclosure of the name of the shipyard is required.

    2.

    We note your response to comment 1 from our letter dated May 25, 2010 with
respect to information regarding potential liability in the event that your employees
or any of your products are involved in an event that leads to property damage,
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
covered, and the applicable policy limits and deductibles and should address, without
limitation, your insurance coverage with respect to any liability related to any
resulting negative environmental effects. In addition, please describe to us the
allocation of liability and related indemnification obligations set forth in your
customer contracts.

Response: The Company maintains general commercial liability insurance, including excess liability
coverage, with coverage limits and deductibles the Company believes are reasonable in light of its
business operations and the nature of its products and services. The Company’s insurance coverage
also includes certain liability protections for pollution/environmental contamination. The above
coverages are designed to be comprehensive in nature and to protect the Company against potential
liability arising out of its products and services that may result in property damage, personal
injury, death or environmental damage. While most potential claims should be covered under the
Company’s policies, the Company’s insurance policies are subject to certain exclusions — the
applicability of such exclusions will depend mostly on the facts and circumstances of each event.
Thus, not all events resulting in potential liability to the Company are necessarily covered under
the Company’s existing insurance program. Furthermore, the dollar amount of any liabilities
covered by the policies may exceed our policy limits. Obtaining additional insurance coverage
amounts designed to cover the maximum amount of any potential claim that could be brought against
the Company, however, is not commercially feasible, as the Company cannot anticipate the maximum
dollar value of a claim it may become subject to in the future. The Company has set the coverage
limits for its insurance program based on a variety of factors, including its historical operating
experience, claims history, standard industry practice and the commercial feasibility of obtaining
such coverage.

Our contracts are separately negotiated with each of our customers. For the Company’s larger
orders, each customer has its own form agreement that is often used as the starting point of the
negotiation. As a result, the allocation of liability and related indemnification obligations vary
from contract to contract, since each of these contracts is separately negotiated. We generally
request certain damage limitations and the exclusion of certain types of damages (such as
consequential damages); however, the resulting allocation of liability and indemnification
obligations is varied from contact to contract. Further, the types of contracts the Company enters
into are different in nature and structure, depending on which business group/product it is for.
As the Company has thousands of contracts in place, with each providing for different

U. S. Securities and Exchange Commission

August 5, 2010

Page 3 of 3

allocations of liability and indemnification, the Company does not believe it would be feasible to
discuss such allocation for each contract, nor would it be meaningful to investors.

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 historical information you provided in the
first full paragraph on page 6 of your response letter.

Response: We will include in future proxy statements the historical information provided in the
first full paragraph on page 6 of our Initial Response Letter.

In providing this response letter to the Staff, the Company acknowledges that (i) the Company is
responsible for the adequacy and accuracy of the disclosure in the above-referenced filings, (ii)
Staff comments or changes to disclosure in response to comments do not foreclose the Commission
from taking any action with respect to the above-referenced filings, and (iii) 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.

If you or any member of the Staff has any questions regarding the responses set forth herein,
please contact the undersigned at (713) 346-7550.

    Sincerely,

    /s/ Dwight W. Rettig

    Dwight W. Rettig

Senior Vice President, General Counsel
and Secretary