William F. Osbourn, Jr.

Executive Vice President and

Chief Financial Officer

Xerox Corporation

201 Merritt 7

Norwalk, CT 06851

Bill.Osbourn@xerox.com

tel 203.849.2483

fax 203.849.2606

April 18, 2019

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Information Technologies and Services

100 F Street, N.E.

Washington, D.C. 20549

Attn: Ryan Rohn and Craig Wilson

Re:    Xerox Corporation

Form 10-K for the Fiscal Year ended December 31, 2018

Filed February 25, 2019

File No. 001-04471

Dear Mr. Rohn and Mr. Wilson:

Reference is made to your letter dated April 11, 2019 addressed to Giovanni Visentin, Chief Executive Officer of Xerox Corporation (the “Registrant” or the “Company”). Our response to the comment raised in your letter is set forth in the attached.

If you have any questions or comments with respect to our response to your comment addressed in this letter, please do not hesitate to call me at 203-849-2483 or Joseph H. Mancini, Jr., Vice President and Chief Accounting Officer, at 203-849-2533.

Sincerely,

/S/ WILLIAM F. OSBOURN, JR.

William F. Osbourn, Jr.

Executive Vice President and Chief Financial Officer

C:    J.H. Mancini, Jr.

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