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November 27, 2019
Judith F. Marks
President and Chief Executive Officer
Otis Worldwide Corporation
One Carrier Place
Farmington, CT 06032
Re: Otis Worldwide Corporation
Amendment No. 2 to
Draft Registration Statement on Form 10
Submitted November 15, 2019
CIK No. 0001781335
Dear Ms. Marks:
We have reviewed your amended draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.
Amended Form 10 filed November 15, 2019
General
1. Please revise to disclose provisions in your Amended and Restated
Certificate of
Incorporation and Amended and Restated Bylaws relating to the rights of
stockholders to
call special meetings and to act by written consent.
Judith F. Marks
Otis Worldwide Corporation
November 27, 2019
Page 2
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
questions.
FirstName LastNameJudith F. Marks Sincerely,
Comapany NameOtis Worldwide Corporation
Division of
Corporation Finance
November 27, 2019 Page 2 Office of
Manufacturing
FirstName LastName