June 10, 2019

Karen Rapp
EVP and Chief Financial Officer
National Instruments Corporation
11500 North MoPac Expressway
Austin, TX 78759

       Re: National Instruments Corporation
           Form 10-K for the fiscal year ended December 31, 2018
           Filed February 21, 2019
           File No. 000-25426

Dear Ms. Rapp:

       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 to these comments, we may have additional
comments.

Form 10-K for the fiscal year ended December 31, 2018

Note 1 - Operations and Summary of Significant Accounting Policies
Revenue Recognition, page F-9

1.    Please tell us how you determine standalone selling price for your
software licenses. In
      this regard, you disclose here that you have established pricing
practices for software
      licenses bundled with maintenance, which are separately observable in
renewal
      transactions. Please tell us what observable renewal transactions are
available as it relates
      to the perpetual licenses or explain further what other methodologies are
used to
      determine the standalone selling price for such licenses. Also, tell us
the amount of
      revenue recognized from software licenses for each period presented. To
the extent you
      have determined that the selling price for your software licenses are
highly variable such
      that you are using the residual method to determine the standalone
selling price, please
      provide a comprehensive, quantitative discussion of such variability to
support your
      conclusion. Refer to ASC 606-10-32-34.
 Karen Rapp
National Instruments Corporation
June 10, 2019
Page 2
Note 14 - Segment Information, page F-37

2.       We note that sales outside of the U.S. accounted for approximately 63%
of your total
         revenue. Please tell us whether any one country generates a
significant amount of
         revenue and if so revise to indicate as such, or specifically state
that no one country meets
         your significance threshold. Refer to ASC 280-10-50-41.
        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 Brittany Ebbertt, Senior Staff Accountant, at
202-551-3572 or
Kathleen Collins, Accounting Branch Chief, at 202-551-3499 with any questions.



                                                                Sincerely,
FirstName LastNameKaren Rapp
                                                                Division of
Corporation Finance
Comapany NameNational Instruments Corporation
                                                                Office of
Information Technologies
June 10, 2019 Page 2                                            and Services
FirstName LastName