TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo September 16, 2020 Walter G. Borst Chief Financial Officer NAVISTAR INTERNATIONAL CORP 2701 Navistar Drive Lisle, IL 60532 Re: NAVISTAR INTERNATIONAL CORP Form 10-K for the Year Ended October 31, 2019 Filed December 17, 2019 File No. 001-09618 Dear Mr. Borst: We have completed our review of your filings. 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. Sincerely, Division of Corporation Finance Office of Manufacturing