August 8, 2018

Christopher Chapman
Chief Financial Officer
Diebold Nixdorf, Incorporated
5995 Mayfair Road
PO Box 3077
North Canton, OH 44720

       Re: Diebold Nixdorf, Incorporated
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed February 28, 2018
           Form 10-Q for the Quarterly Period Ended June 30, 2018
           Filed August 6, 2018
           File No. 001-04879

Dear Mr. Chapman:

       We have limited our review of your filings to the financial statements
and related
disclosures 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, 2017

Consolidated Statements of Operations, page 53

1.    Please revise to separately disclose software revenue from services. To
the extent that
      software revenue is less than 10% of total revenue, explain your basis
for including this
      revenue with services rather than products. We refer you to Rule 5-03 of
Regulation S-X.
 Christopher Chapman
FirstName LastNameChristopher Chapman
Diebold Nixdorf, Incorporated
Comapany2018
August 8, NameDiebold Nixdorf, Incorporated
August 8, 2018 Page 2
Page 2
FirstName LastName
Form 10-Q for the Quarterly Period Ended June 30, 2018

Notes to Condensed Consolidated Financial Statements
Note 2. Revenue, page 9

2.       You disclose on page 9 that the consideration specified in the
contract excludes sales
         incentives. Please reconcile this with your disclosure on page 12 that
the transaction price
         includes variable consideration, which would appear to include sales
incentives.
         Also, revise your disclosure to specify the types of variable
consideration as well as how
         you measure obligations for returns and refunds. Refer to ASC
606-10-50-20.
3.       Please describe for us the nature of the professional services
provided that modify the
         intellectual property such that they are not distinct from the
software. Provide us with
         your analysis of the factors considered in determining that the
services significantly
         modify or customize the software and are therefore accounted for as a
single performance
         obligation. Refer to 606-10-25-21(b).
4.       Please tell us whether customized software arrangements include
customer acceptance
         provisions and how these provisions are considered when recognizing
revenue.
5.       Please tell us why the standalone selling price of software licences
is typically estimated
         using the residual approach and how you met one of the criteria in ASC
606-10-32-34(c).
         To the extent you have determined the selling price for your software
is highly variable;
         provide a comprehensive, quantitative discussion of such variability
to support your
         conclusions.
6.       We note that some professional service revenues are recognized ratably
and some using
         input measures, typically costs incurred. However, you also disclose
on page 12 that you
         use the "as invoiced" practical expedient for performance obligations
satisfied over time.
         Please revise to clarify which performance obligations are recognized
using the "as
         invoiced" practical expedient.
General

7.       On your website you list Sudan as a country where you have banking
partners and you
         identify Tanglewood Investments Ltd. and ISTINARA MATC as your
business partners
         in that country. Sudan is designated by the State Department as a
state sponsor of
         terrorism, and is subject to U.S. export controls. Please describe to
us the nature and
         extent of your past, current and anticipated contacts with Sudan,
including contacts with
         its government, whether through subsidiaries, business partners or
other direct or indirect
         arrangements. 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 Sudan for the last three fiscal years and
the subsequent interim
         period. Address for us the potential impact of the investor sentiment
evidenced by
 Christopher Chapman
Diebold Nixdorf, Incorporated
August 8, 2018
Page 3
         divestment and similar initiatives that have been directed toward
companies that have
         operations associated with U.S.-designated state sponsors of
terrorism.
       In closing, 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 David Edgar, Staff Accountant, at (202) 551-3459 or
Christine Dietz,
Assistant Chief Accountant, at (202) 551-3408 with any questions.



                                                             Sincerely,
FirstName LastNameChristopher Chapman
                                                             Division of
Corporation Finance
Comapany NameDiebold Nixdorf, Incorporated
                                                             Office of
Information Technologies
August 8, 2018 Page 3                                        and Services
FirstName LastName