October 4, 2024

Thomas S. Timko
Executive Vice President and Chief Financial Officer
Diebold Nixdorf, Incorporated
350 Orchard Avenue NE
North Canto, OH 44720

       Re: Diebold Nixdorf, Incorporated
           Form 10-K for the Fiscal Year Ended December 31, 2023
           Form 8-K furnished on February 14, 2024
           Response dated September 26, 2024
           File No. 001-04879
Dear Thomas S. Timko:

       We have reviewed your September 26, 2024 response to our comment letter
and have the
following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

        After reviewing your response to this letter, we may have additional
comments. Unless we
note otherwise, any references to prior comments are to comments in our
September 12, 2024
letter.

Form 10-K for the Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 26

1.     Your response to prior comment 1 indicates that you will remove the
non-GAAP
       combined presentation that adjusts to exclude the impact of fresh start
accounting;
       however, your response also indicates that in future filings you intend
to provide the
       combined amounts without any adjustments as    Non-GAAP combined   . A
presentation
       that merely combines the predecessor and successor periods would not be
appropriate
       given that the predecessor and successor periods are not comparable.
Please confirm that
       you will not present combined results in future filings and that your
MD&A discussion
       will be limited to a discussion of historical results that separately
compares the historical
       results of the respective successor and predecessor periods.
 October 4, 2024
Page 2

Form 8-K furnished on February 14, 2024
Non-GAAP Financial Measures and Other Information, page 3

2.     We note your response to prior comment 1 does not address the
presentations in your
       earnings releases on Form 8-K. Please confirm you will also remove the
combined
       presentation and other non-GAAP measures that adjust to exclude the
impact of fresh start
       accounting from future filings.
3.     We note your response to prior comment 3. Please provide us with a more
detailed
       explanation of the nature of and quantitative breakdown of
professional fees (legal and
       consulting).    Also, we note that your disclosures on page 85 of the
Form 10-K indicate
       that the charges relate to streamlining operations, driving efficiencies
and digitizing
       processes and on page 17 of the Form 10-Q you disclose that the
continuous improvement
       initiative focused on innovating your solutions to support a better
transaction experience
       for consumers at bank and retail locations through the integration of
hardware, software
       and services. Please explain, in detail, how you determined that these
costs do not
       represent normal, recurring, cash operating expenses necessary to
operate your business.
       Refer to Question 100.01 of the non-GAAP C&DIs.
       Please contact Chen Chen at 202-551-7351 or Christine Dietz at
202-551-3408 if you
have questions regarding comments on the financial statements and related
matters.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Technology
cc:   Elizabeth Radigan