March 11, 2019

David J. Endicott
Chief Executive Officer
Alcon Inc.
Rue Louis-d'Affry 6
1701 Fribourg, Switzerland

       Re: Alcon Inc.
           Amendment No. 4 to Registration Statement on Form 20-F
           Filed February 28, 2019
           File No. 001-31269

Dear Mr. Endicott:

      We have reviewed your amended registration statement 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 business days by providing
the requested
information or advise 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. Unless we note otherwise, our references to prior comments are to
comments in our
February 19, 2019 letter.

Form 20-F amended February 28, 2019

Failure to comply with law..., page 53

1.     We note your response to prior comment 1 providing the aggregate revenue
for the
       referenced geographical locations over the three year period ended
December 31, 2018.
       Tell us the breakdown of revenue for the referenced geographical
location for each fiscal
       year. Also, ensure that your risk factor includes a brief discussion of
each
       allegation subject to the investigations you mention. In this regard, it
is unclear whether
       you are "including" only a partial list of the allegations in your
description in the last full
       sentence on page 53 and the second sentence on page 54. Also, specify
the nature of
       allegations regarding the investigation into your "business practices"
and "relationships
       with third-party distributors."
 David J. Endicott
FirstName LastNameDavid J. Endicott
Alcon Inc.
Comapany2019
March 11, NameAlcon Inc.
Page 2
March 11, 2019 Page 2
FirstName LastName
Audited Combined Financial Statements for the Year Ended December 31, 2018
Note 3. Significant Accounting Policies, Revenue Recognition, page F-18

2.       We note from your response to comment 2 that certain of your contracts
provide for
         consideration to paid in installments with either fixed payment terms
or usage-based
         payment terms (i.e., payments through a surcharge on the subsequent
purchase price of
         consumables and/or implantables). Please address the following:

             Describe to us in greater detail the usage-based payment terms and
how you account
             for the surcharge on the subsequent purchases. We note that your
disclosure of the
             common elements of variable consideration on page F-19 does not
include discussion
             of usage-based payment terms, and you do not appear to disclose
any contract assets
             for equipment transferred before payment is due through subsequent
usage.
             Describe to us the period over which you typically receive payment
for installment
             sales.
             Tell us how you applied the guidance in IFRS 15.60-15.65 with
respect to the
             existence of a significant financing component in the contracts.
             Tell us your consideration of IFRS 15.119(b)'s requirement to
disclose information
             about the significant payment terms (e.g., when payment is
typically due, whether the
             contract has a significant financing component, etc.) and IFRS
15.129's requirement to
             disclose application of the practical expedient related to
significant financing
             components.
             Describe to us how the consideration for the equipment sale that
represents a surcharge
             on the subsequent purchase price of consumables and/or
implantables is presented in
             your disclosure of net sales by business franchise on page F-30.
In this regard, it is
             unclear whether the surcharge is captured as part of
"Equipment/other" or within the
             respective "Implantables" or "Consumables" business franchise.

         Please tell us whether the customer has the right to put the equipment
back to you and
         whether you have to the right to retake control of the equipment. If
so, please explain to
         us the terms surrounding such right(s) and how you account for these
rights.
 David J. Endicott
Alcon Inc.
March 11, 2019
Page 3

        You may contact Kristin Lochhead at 202-551-3664 or Brian Cascio,
Accounting Branch
Chief, at 202-551-3676 if you have questions regarding comments on the
financial statements
and related matters. Please contact Heather Percival at 202-551-3498 or Amanda
Ravitz,
Assistant Director, at 202-551-3412 with any other questions.



                                                        Sincerely,
FirstName LastNameDavid J. Endicott
                                                        Division of Corporation
Finance
Comapany NameAlcon Inc.
                                                        Office of Electronics
and Machinery
March 11, 2019 Page 3
cc:       D. Scott Bennett
FirstName LastName