Mail Stop 4628

                                                             November 14, 2018

Via E-mail
Andre J. Fernandez
Chief Financial Officer
NCR Corporation
864 Spring Street NW
Atlanta, GA 30308

       Re:     NCR Corporation
               10-K for Fiscal Year Ended December 31, 2017
               Filed February 26, 2018
               File No. 1-00395

Dear Mr. Fernandez:

        We have limited our review of your filing to your contacts with
countries that have been
identified as state sponsors of terrorism, and we have the following comment.
Our review with
respect to this issue does not preclude further review by the Assistant
Director group with respect
to other issues. In our comment, we ask you to provide us with information so
we may better
understand your disclosure.

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

       After reviewing your response to this comment, we may have additional
comments.

General

1.     You indicate on page 86 of the 10-K that you may have had a Syrian
branch, two
       employees and property in Syria as recently as April 2016. Additionally,
you state on
       page 36 of the 10-K filed February 24, 2017 that you maintained a bank
account and
       guarantees at the Commercial Bank of Syria between January 1, 2016 and
April 30, 2016.
       We are aware of news reports which appear to indicate that Commercial
Bank of Syria
       operates NCR ATMs. Finally, you provide on page 29 of the 10-K revenue
figures by
       "geographic theater" including for "Europe, Middle East Africa (EMEA),"
a region that
       includes Sudan and Syria.

       As you know, Sudan and Syria are designated by the Department of State
as state
       sponsors of terrorism, and are subject to U.S. economic sanctions and/or
export controls.
       Please describe to us the nature and extent of any past, current, and
anticipated contacts
 Andre J. Fernandez
NCR Corporation
November 14, 2018
Page 2
       with Sudan and Syria since your letter to us dated November 18, 2015,
including contacts
       with their governments, whether through subsidiaries, affiliates,
distributors, partners,
       resellers, customers, joint ventures or other direct or indirect
arrangements. Please also
       discuss the materiality of those contacts, in quantitative terms and in
terms of qualitative
       factors that a reasonable investor would deem important in making an
investment
       decision. Tell us the approximate dollar amounts of revenues, assets and
liabilities
       associated with those countries for the last three fiscal years and the
subsequent interim
       period. Address for us the potential impact of the investor sentiment
evidenced by
       divestment and similar initiatives that have been directed toward
companies that have
       operations associated with U.S.-designated state sponsors of terrorism.

        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.

        You may contact Daniel Leslie, Staff Attorney, at (202) 551-3876 or me
at (202) 551-
3470 if you have any questions about the comment or our review.

                                                             Sincerely,

                                                             /s/ Cecilia Blye

                                                             Cecilia Blye,
Chief
                                                             Office of Global
Security Risk

cc:
       Barbara Jacobs
       Assistant Director
       Division of Corporation Finance