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    National Oilwell Varco, Inc.

    7909 Parkwood Circle Drive

    Houston, TX 77036

    PHONE 713-346-7500

    FAX 713-346-7995

January 7, 2011

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”)

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”) on December 27, 2010 by letter dated December 10, 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.

General

    1.

    We note your response to comment 2 from our letter dated September 10, 2010,
and your statement that you believe certain information that you provided is
commercially sensitive and could be harmful to you if publicly disclosed. Please
provide to us your basis for such belief. In addition, please provide to us an
expanded discussion of the “various common conditions and exclusions” that you
reference in your response. In that regard, please tell us the nature of such
conditions and exclusions, and provide relevant examples.

Response: The information redacted from our prior response could be used by the Company’s
competitors to better understand the Company’s cost structure, which could have an adverse effect
on the Company’s ability to successfully bid for new projects. Therefore, public disclosure of
this commercially sensitive information could be harmful to the Company. The Company’s insurance
policies include common conditions and exclusions for insurance policies written to cover a
multistate and multinational manufacturer of large capital equipment, including exclusions for
bodily injury or property damage arising out of the use of asbestos in products, the ownership or
use of

aircraft and watercraft, or property damage to the Company’s own equipment as a result of equipment
failure.

    2.

    We note the article published by Reuters on December 6, 2010 regarding your
role in the White House Oil Spill Commission’s probe of the Deepwater Horizon
incident. Please tell us what consideration you gave to providing disclosure
regarding your involvement in the Deepwater Horizon incident, in your filings. For
example, and without limitation, please tell us what consideration you gave to
providing related legal proceeding or risk factor disclosure.

Response: The Company’s equipment was not involved in the Deepwater Horizon incident and the
Company has not been sued in any of the related litigation. Therefore, the Company does not
believe any disclosure regarding the incident in its filings is necessary or useful to investors.

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