September 12, 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 reviewed your August 17, 2018 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to
comments in our
August 8, 2018 letter.

Form 10-Q for the Quarterly Period Ended June 30, 2018

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

1.    We note your response to prior comment 3. Please describe the nature of
the professional
      services and the intellectual property (IP) and provide us with a
comprehensive analysis
      explaining how the IP and professional services are not distinct. Ensure
that you describe
      in detail how the professional services customize the IP.
 Christopher Chapman
Diebold Nixdorf, Incorporated
September 12, 2018
Page 2
2.       Based on your response to prior comment 4, it appears that your
contracts may not include
         customer acceptance provisions and when they do, those provisions do
not impact the
         timing of revenue recognition. However, in your Form 10-K filed
February 28, 2018, you
         disclosed that generally the earnings process is complete upon
customer acceptance and
         you seem to indicate there are customer acceptance provisions in
various types of
         contracts. Please clarify for us which of your contacts contain
acceptance provisions,
         describe the nature of these provisions and how you considered whether
they were a
         formality that would not affect your determination of when your
customer obtains control
         of the good or service. Refer to ASC 606-10-25-30(e) and see
606-10-55-86 and -87 for
         further guidance.
3.       We note your response to prior comment 5. Given you have concluded you
have limited
         history of standalone sales necessary to accurately establish a
standalone selling price, tell
         us how you evaluated other methods to estimate a standalone selling
price for your
         software licenses, such as an adjusted market assessment approach or
an expected cost
         plus a margin approach as discussed in ASC 606-10-32-34. Further, tell
us if and how
         you considered whether the selling price of the software is highly
variable. As part of
         your response, please quantify the amount of revenue recognized for
distinct software
         licenses where the residual method is used.
        You may contact David Edgar, Staff Accountant, at (202) 551-3459 or
Christine
Dietz, Assistant Chief Accountant, at (202) 551-3408 if you have questions
regarding comments
on the financial statements and related matters.



                                                                Sincerely,
FirstName LastNameChristopher Chapman
                                                                Division of
Corporation Finance
Comapany NameDiebold Nixdorf, Incorporated
                                                                Office of
Information Technologies
September 12, 2018 Page 2                                       and Services
FirstName LastName