February 21, 2020

Judith F. Marks
President and Chief Executive Officer
Otis Worldwide Corporation
One Carrier Place
Farmington, CT 06032

       Re: Otis Worldwide Corporation
           Registration Statement on Form 10
           Filed February 7, 2020
           File No. 001-39221

Dear Ms. Marks:

       We have reviewed your filing 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 and any amendment you may file in response
to these
comments, we may have additional comments.

Form 10 Registration Statement

Unaudited Pro Forma Combined Financial Information
Notes to the Unaudited Pro Forma Combined Financial Information, page 61

1.    Refer to Note 2(F) on page 62. Given that you will incur a substantial
amount of
      indebtedness in connection with the separation and distribution, please
give consideration
      to including in a tabular format, the individual amounts pertaining to
each debt category.
      In this regard, disclose the aggregated amount, range of interest rates
and range of
      maturity dates of the unsubordinated debt, unsecured notes, and term
loans.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
 Judith F. Marks
Otis Worldwide Corporation
February 21, 2020
Page 2

        You may contact Beverly Singleton at 202-551-3328 or Claire Erlanger at
202-551-
3301 if you have questions regarding comments on the financial statements and
related
matters. Please contact John Stickel at 202-551-3324 or John Dana Brown at
202-551-3859 with
any other questions.



FirstName LastNameJudith F. Marks                        Sincerely,
Comapany NameOtis Worldwide Corporation
                                                         Division of
Corporation Finance
February 21, 2020 Page 2                                 Office of Finance
FirstName LastName