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CORRESP
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CORRESP

 SKADDEN, ARPS, SLATE, MEAGHER &
FLOM LLP

 ONE MANHATTAN WEST

NEW YORK, NY 10001

 TEL: (212)
735-3000

 FAX: (212) 735-2000

www.skadden.com

July 21, 2023

 FIRM/AFFILIATE

OFFICES

 BOSTON

CHICAGO

 HOUSTON

LOS ANGELES

 PALO ALTO

WASHINGTON, D.C.

 WILMINGTON

 BEIJING

BRUSSELS

 FRANKFURT

HONG KONG

 LONDON

MUNICH

 PARIS

SÃO PAULO

 SEOUL

SHANGHAI

 SINGAPORE

TOKYO

 TORONTO

 SUBMISSION VIA EDGAR

Office of Technology

 Division of Corporation Finance

United States Securities and Exchange Commission

 100 F Street,
N.E.

 Washington, D.C. 20549

Attn:

Kathleen Collins

Matthew Derby

Melissa Kindelan

Mariam Mansaray

Re:

NCR ATMCo, LLC

Registration Statement on Form 10-12B

Filed June 26, 2023

File No. 001-41728

 Ladies and Gentlemen:

On behalf of NCR ATMCo, LLC (the “Company” or “NCR ATMCo”), a wholly owned subsidiary of NCR
Corporation (“NCR”), and in response to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on the Company’s
Registration Statement on Form 10 (the “Registration Statement”) set forth in your comment letter dated July 11, 2023 (the “Comment Letter”), set forth below are the Company’s responses to
the Comment Letter. The Company has revised the Registration Statement and is filing Amendment No. 1 to the Registration Statement (the “Amended Registration Statement”), including an information statement
filed therewith (“Information Statement”) concurrently herewith.

 The headings and paragraph numbers in this
letter correspond to those contained in the Comment Letter and, to facilitate the Staff’s review, we have reproduced the text of the Staff’s comments in italics below. Capitalized terms used but not defined herein have the meanings given
to them in the Amended Registration Statement. All references to page numbers and captions (unless otherwise stated) in our responses correspond to the page numbers and captions in the Information Statement included in the Amended Registration
Statement.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

July 21, 2023

  Page
 2

 Registration Statement on Form 10-12B

Notes to Unaudited Pro Forma Combined Financial Statements, page 91

1.
 We note pro forma adjustment (r) reflects incremental stock compensation expense related
to adjustments made to accelerate vesting of certain equity awards. We also note on page F-64 you disclose that 50% of the market-based restricted stock units granted include an accelerated vesting provision
if a spin-off takes place during the performance period. Please tell us whether adjustment (r) relates to these awards and this accelerated vesting provision. If so, tell us how the
additional expense of $4 million relates to 50% of the awards, which appears to have unrecognized compensation costs of $50 million as of March 31, 2023. Also, revise to reflect this
adjustment as of the beginning of the fiscal year presented (i.e. January 1, 2022). Lastly, tell us why this adjustment is reflected as an autonomous entity adjustment rather than a transaction accounting adjustment.

 Response: We respectfully acknowledge the Staff’s comment and affirm on behalf of the Company that the
additional stock compensation expense in adjustment (n) relates to the market-based restricted stock units granted in December 2022 and February 2023 which for a portion of the awards include pre-existing
provisions in the award agreements that require the vesting period to be reduced from 36 months to the later of (i) the spin-off date and (ii) 12 months in the event a
spin-off occurred (which is summarized on page F-64).

 We
have been advised by the Company that in determining the incremental stock compensation expense of $4 million in adjustment (n), the Company considered all unrecognized compensation cost related to unvested restricted stock unit grants specific
to employees who exclusively support NCR ATMCo operations (i.e., $50 million as of March 31, 2023). The population of all unrecognized compensation costs include several grants which do not include a
pre-existing provision requiring reduction of the vesting period in the event of a spin-off ($36 million); only the two most recent grants (December 2022 and February
2023) include a provision that shortens the vesting period in the event of a spin-off ($14 million). Of those grants which include such provision, 50% of the award had a reduction in the vesting period (from
36 months to the later of (i) the spin-off date and (ii) 12 months) and the resulting additional stock compensation expense is included within adjustment (n).

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

July 21, 2023

  Page
 3

 With respect to the Staff’s comment regarding the period in which the pro forma
adjustment (n) is reflected, the Company has advised us that the awards with the accelerated vesting provision were granted in December 2022 and February 2023 as part of the annual granting process of NCR. Given the nature of the awards, which
were granted in the normal course of business, the Company determined such underlying grants did not represent a material event or condition for which a pro forma effect should be given. Instead, the Company is prospectively giving pro forma effect
to the change in vesting period triggered by the spin-off from 36 months to the later of (i) the spin-off date and (ii) 12 months. Therefore, the Company did
not push back the expense any earlier than when the awards were granted. As awards were first granted in December 2022, the change of vesting position had no material impact to the annual period, and therefore, the Company did not reflect a pro
forma adjustment for the year ended December 31, 2022. However, a pro forma adjustment of $4 million for the three-month interim period ended March 31, 2023 was reflected. We respectfully advise the Staff that the Company has revised
the disclosure on page 91 of the Information Statement for adjustment (n) accordingly.

 We further respectfully advise the Staff
that, upon further evaluation and in response to the Staff’s comment, the Company has revised adjustment (n) (which was previously adjustment (r) in the Information Statement filed on June 26, 2023) on pages 86 and 91 of the
Information Statement to be reflected as a transaction accounting adjustment rather than an autonomous entity adjustment.

 Business, page 95

2.
 With a view towards revised disclosure, advise whether NCR ATMCo is dependent on any platforms to liquidate
its Bitcoin or other crypto assets or convert such crypto assets into fiat currency. Address the company’s reliance on any such platform.

Response: The Company is not dependent on any single platform to trade in Bitcoin and in accordance with its Business Continuity and
Disaster Recovery Plan it maintains at least two active accounts at multiple cryptocurrency exchanges to avoid reliance on a single service provider. As a holder of Bitcoin, the Company is subject to the risks associated with holding Bitcoin,
including the risk of loss because it may not be able to liquidate its Bitcoin holdings at desired prices due to fluctuations in market prices or loss of access to its digital wallets, including through an exchange’s bankruptcy or cybercrime.
The Company mitigates this risk through maintaining limited Bitcoin holdings and targets to maintain a Bitcoin balance that does not exceed $0.5 million in value. The average value of the Company’s Bitcoin balance was approximately
$0.5 million in 2022 and approximately $0.4 million to date in 2023.

 While the Company does not consider the operations of its
LibertyX business (the business line that utilizes Bitcoin) material to its overall operations or business, in response to the Staff’s comment, additional disclosure has been included on pages 104 and 105 of the Information Statement.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

July 21, 2023

  Page
 4

3.
 We note your response to prior comment 6. Please revise to discuss the geographic areas you currently offer
Bitcoin related services, including buying, selling and sending remittances.

 Response: In response to the
Staff’s comment, additional disclosure has been included on pages 104 and 105 of the Information Statement which provides that, among other things, the Company’s LibertyX business, through its LibertyX platform, offers customers the
ability to purchase Bitcoin in most of the U.S. and through its LibertyPay platform offers customers only in Alabama, Delaware, Florida, Massachusetts, Mississippi, Oregon, Pennsylvania and Washington, the ability to transmit money overseas
(outbound transmission only).

 We respectfully further advise the Staff that, LibertyPay generated $5 million of revenue in fiscal
year 2022, less than 0.2% of NCR ATMCo revenue, which management considers to be an immaterial revenue stream. In addition, other than for transactions where payments are directed to individuals in Brazil, all transactions on the LibertyPay platform
are processed on behalf of the Company by a third-party money transmitter. With respect to Brazil, the Company processes transactions in Brazil directly through a Brazilian subsidiary and maintains a balance of local currency in Brazil in order to
facilitate these transactions. To maintain those local currency balances the Company uses Bitcoin as an internal cash management tool to convert funds from U.S. dollars into Brazilian reals. The Company believes that using a public blockchain for
intercompany transfers is faster, cheaper, and more secure than using traditional means. Customers using LibertyPay do not receive Bitcoin or any other virtual currency, nor are they directly exposed to Bitcoin or any other virtual currency in any
manner. The Company also maintains the capability to move funds to its Brazilian subsidiary by traditional means if necessary to complete transactions on the LibertyPay platform.

Government Regulations, page 108

4.
 Please revise to provide a more complete discussion regarding the regulatory requirements for offering
cross-border remittances in Bitcoin as well as your other Bitcoin services. As non-exclusive examples, discuss the anti-money laundering and know-your-customer requirements for buying, selling or transacting
in Bitcoin and any licenses currently held and those that may be required.

 Response: In response to the
Staff’s comment, additional disclosure has been included on page 109 of the Information Statement.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

July 21, 2023

  Page
 5

 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
112

5.
 We note your response to prior comment 9, and reissue in part. There are various instances throughout your
results of operations discussion where you cite two or more factors as contributing to the variance in a certain line item. For example, on page 129 you state that, “Self-Service Banking Adjusted EBITDA decreased 9% for the year ended
December 31, 2022, compared to the prior year period primarily due to supply chain challenges and increased fuel costs which drove up component and other costs, particularly in ATM hardware, hardware maintenance and transaction
services. These headwinds were partially offset by an increase in recurring revenue.” Please revise throughout to quantify each material factor, including any offsetting factor(s) that contributed to such change. In addition, refrain
from using qualitative terms such as “primarily” in lieu of providing specific quantitative disclosure. Refer to Item 303(b) of Regulation S-K.

Response: We respectfully acknowledge the Staff’s comment and advise the Staff on behalf of the Company that management carefully
evaluated the discussion of the Company’s results of operations to identify changes in line items in the periods presented and to discuss and quantify any material factor, including any offsetting factor(s), that contributed to such change in
accordance with Item 303(b) of Regulation S-K. We respectfully advise the Staff that the Company has revised its disclosure in its results of operations to quantify the reasons contributing to the material
changes from period-to-period. We further advise the Staff on behalf of the Company that, other than what is described in the revised disclosure, no other material items
were identified for disclosure under Item 303(b) of Regulation S-K. The Company’s management will monitor the disclosure in future filings and include both quantitative and qualitative disclosure when
describing the underlying reasons for material changes from period-to-period in one or more line items.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

July 21, 2023

  Page
 6

 Key Strategic Financial and Performance Metrics, page 118

6.
 Please revise to clarify whether the number of ATMs included in the ATM-as-a-Service metric are also included in the Total Units Owned/Managed/Serviced count. If so, tell us and revise to explain why the Total Units
Owned/Managed/Serviced have steadily declined since fiscal 2021 and how that trend is impacting your business.

Response: We respectfully acknowledge the Staff’s comment and advise the Staff that the Company has informed us that its metric of
Total Units Owned / Managed / Serviced includes the ATM-as-a-Service units. Management believes Total Units Owned / Managed /
Serviced to be a useful metric as it reflects the size and reach of the Company’s business as well as indicates potential growth or decline in certain revenue streams. Examples of factors that impact the total number of units include new
customers (through organic growth or acquisitions), business closures, compliance requirements, contract terminations or expansions, bank consolidation through acquisition and bank fleet and physical location rationalization. The decline in Total
Units Owned / Managed / Serviced from 2021 is largely driven by a decline in legacy Cardtronics contracts, as a result of actively not seeking renewal of un-profitable contracts, and a decline in the
traditional hardware maintenance and other services due to footprint rationalization and non-renewals. We further respectfully advise the Staff on behalf of the Company that, given the diversification of the
Company’s portfolio of Total Units Owned / Managed / Serviced, the Company believes the decline does not result in a material impact to the Company’s business because of its mix of revenues. Specifically, the unit decline in the
Company’s legacy Cardtronics contracts are offset by increases in Owned/ATM-as-a-Service contracts that allow the Company to
earn a greater proportion of recurring revenue from customers. Rather, this is consistent with the Company’s strategy to shift the traditional ATM business to the recurring ATM-as-a-Service model as outlined on page 119 of the Information Statement, which can impact the number of total number of units.

We respectfully advise the Staff that we have made the requested revisions on pages 23, 118 and 119 of the Information Statement.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

July 21, 2023

  Page
 7

 Revenue and Adjusted EBITDA by Segment, page 127

7.
 We note your revised presentation in response to prior comment 10. Please further revise to remove footnote
(4) here and on page 128, since you no longer include Corporate and Other in the tables.

Response: We acknowledge the Staff’s comment and respectfully advise the Staff that we have made the requested revision on pages
128 and 129 of the Information Statement.

 Financial Condition, Liquidity and Capital Resources

Sources of Historical Liquidity, page 130

8.
 We note your response