August 29, 2019

Judith F. Marks
President and Chief Executive Officer
Otis Worldwide Corporation
One Carrier Place
Farmington, CT 06032

       Re: Otis Worldwide Corporation
           Draft Registration Statement on Form 10
           Submitted August 9, 2019
           CIK No. 0001781335

Dear Ms. Marks:

       We have reviewed your filing and have the following comments. In some of
comments, we may ask you to provide us with information so we may better
understand your

       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

     After reviewing your response and any amendment you may file in response
to these
comments, we may have additional comments.

Draft Registration Statement Submitted August 9, 2019

General, page i

1.    Please confirm in a cover letter to the nonpublic draft submission that
you will publicly
      file your registration statement and nonpublic draft submissions at least
15 days prior to
      the anticipated effective date of the registration statement for your
listing on a national
      securities exchange.
2.    We note that your forum selection provision identifies the Court of
Chancery of the State
      of Delaware as the exclusive forum for certain litigation, including any
      action." Please disclose whether this provision applies to actions
arising under the
      Securities Act or Exchange Act. In that regard, we note that Section 27
of the Exchange
      Act creates exclusive federal jurisdiction over all suits brought to
enforce any duty or
      liability created by the Exchange Act or the rules and regulations
thereunder, and Section
      22 of the Securities Act creates concurrent jurisdiction for federal and
state courts over all
 Judith F. Marks
FirstName LastNameJudith F. Marks
Otis Worldwide Corporation
Comapany NameOtis Worldwide Corporation
August 29, 2019
August 29, 2019 Page 2
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FirstName LastName
         suits brought to enforce any duty or liability created by the
Securities Act or the rules and
         regulations thereunder. If the provision applies to Securities Act
claims, please also revise
         your prospectus to state that there is uncertainty as to whether a
court would enforce such
         provision and that investors cannot waive compliance with the federal
securities laws and
         the rules and regulations thereunder. If this provision does not apply
to actions arising
         under the Securities Act or Exchange Act, please also ensure that the
exclusive forum
         provision in the governing documents states this clearly, or tell us
how you will inform
         investors in future filings that the provision does not apply to any
actions arising under the
         Securities Act or Exchange Act.
The Separation and Distribution, page 15

3.       Please briefly identify the assets as well as liabilities and
obligations to be allocated
         pursuant to the Separation and Distribution Agreement and other
ancillary agreements.
Risk Factors, page 21

4.       Consistent with your disclosure on page 65, please add a risk factor
or update an existing
         risk factor to discuss the fact that your new equipment unit sales in
China represent over
         half of our global sales by unit volume.
Your percentage of ownership in Otis may be diluted in the future, page 37

5.       Please disclose here information concerning plans, if any, to issue
equity awards to
         directors, officers and other employees, as well as any acquisitions
or capital market
         transactions you are presently considering.
Cautionary Note Regarding Forward-Looking Statements, page 40

6.       We note the reference to the safe harbor provided by the Private
Securities Litigation
         Reform Act of 1995. Please tell us why you believe the safe harbor is
available to you.
         Refer to Section 21E of the Exchange Act.
Unaudited Combined Pro Forma Financial Information
Note 2. Pro Forma Adjustments, page 60

7.       We note your disclosure under Executive Compensation and Director
Compensation that
         prior to effectiveness, compensation for Executives and Directors will
be finalized. If
         there are new compensation contracts that are directly a result of the
merger and factually
         supportable, please revise your pro forma financial statements to
include disclosure of any
         material contractual terms and applicable pro forma adjustments.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page

8.       We note from your disclosure on page 7 that following the
distribution, you will enter into
 Judith F. Marks
FirstName LastNameJudith F. Marks
Otis Worldwide Corporation
Comapany NameOtis Worldwide Corporation
August 29, 2019
August 29, 2019 Page 3
Page 3
FirstName LastName
         a Separation Agreement to effect the separation, and a Transition
Services Agreement, a
         Tax Matters Agreement, an Employee Matters Agreement and Intellectual
         agreement that will govern the relationship between Otis, Carrier and
UTC subsequent to
         the completion of the separation and distribution and provide for the
allocation between
         UTC, Carrier and Otis of UTC's assets, liabilities and obligations
attributable to periods
         prior to the separation from UTC. Once the terms of these agreements
have been
         determined, please revise your disclosure in your MD&A section to
discuss the significant
         amounts and terms related to these agreements.
Off-Balance Sheet Arrangements and Contractual Obligations, page 81

9.       We note that your table of contractual obligations and commitments is
presented as of
         December 31, 2018. In light of the intention to enter into debt
financing arrangements
         prior to or as part of the separation, please consider adding a note
or revising to include a
         pro forma table of contractual obligations which reflects the timing
of payments, if
         significant, related to the new arrangements. Your Liquidity section
should also be
         revised to describe the nature and terms of this new debt.
Combined Financial Statements
Note 18-Contingent Liabilities, page F-36

10.      From your disclosures under Separation Agreement on page 97, we note
that certain
         liabilities, including in respect of environmental or asbestos
matters, will transfer to
         Otis. However, we note that your disclosure in Note 18 does not
mention any asbestos
         matters. Please note that in accordance with ASC 450-20-50-1, the
nature (and possibly
         amount) of any accruals made for a loss contingency should be
disclosed in the notes to
         your financial statements. Also, ASC 450-20-50-3 requires that if no
accrual is made for a
         loss contingency because one or both of the conditions are not met, or
an exposure to loss
         exists in excess of the amount accrued pursuant to the provisions of
ASC 450-20-30-1,
         disclosure of the contingency shall be made when there is at least a
reasonable possibility
         that a loss or an additional loss may have been incurred. The
disclosure shall indicate the
         nature of the contingency and shall give an estimate of the possible
loss or range of loss or
         state that such an estimate cannot be made. Please confirm your
compliance with the
         requirements of ASC 450-20-50 and that you will revise your
disclosures in future filings,
         as applicable.
        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.
 Judith F. Marks
Otis Worldwide Corporation
August 29, 2019
Page 4

       You may contact Effie Simpson at 202-551-3346 or Claire Erlanger at
202-551-3301 if
you have questions regarding comments on the financial statements and related
matters. Please
contact John Stickel at 202-551-3324 or John Dana Brown at 202-551-3859 with
any other

FirstName LastNameJudith F. Marks                         Sincerely,
Comapany NameOtis Worldwide Corporation
                                                          Division of
Corporation Finance
August 29, 2019 Page 4                                    Office of
Transportation and Leisure
FirstName LastName