United States securities and exchange commission logo August 6, 2020 Nora LaFreniere Executive Vice President Otis Worldwide Corporation One Carrier Place Farmington, Connecticut 06032 Re: Otis Worldwide Corporation Registration Statement on Form S-4 Filed July 31, 2020 File No. 333-240272 Dear Ms. LaFreniere: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Thomas Jones at 202-551-3602 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Joshua R. Cammaker, Esq.