CMICummins

In your letter to us dated July 29, 2015, you discussed contacts with Syria and Sudan, countries that are designated by the State Department as state sponsors of terrorism and are subject to U.S. economic sanctions and/or export controls. You do not provide disclosure about Syria or Sudan in your Form 10-K.

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Please describe to us the nature and extent of any past, current, and anticipated contacts with Syria and Sudan since your 2015 letter, whether through subsidiaries, affiliates, customers, joint ventures, or other direct or indirect arrangements. In this regard, we note that your customers Daimler, Volvo and Kamaz reportedly sell vehicles in Syria and Sudan.

The Company does not have any employees or facilities in Syria or Sudan. The Company does not consider its contacts with these countries, either individually or in the aggregate, to be material for purposes of the Commission's disclosure requirements. We discuss each country in greater detail below.

Syria

Cummins complies strictly with the applicable export control laws and economic sanctions related to Syria. As such, the sales of Cummins products in Syria are negligible.

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In March 2017, there was one instance where the Company produced alternators in Romania valued at €60,000.00 (approximately $ 63,450.00) and exported them to support the United Nations mission in Syria. This transaction was authorized under the applicable economic sanctions and export control laws, and was reviewed and approved by the Company pursuant to its own compliance policy. There have been no other contacts with Syria during the Response Period.

Sudan

Cummins complies strictly with the applicable export control laws related to Sudan. As of October 2017, OFAC lifted the comprehensive economic sanctions program that previously limited the engagement of U.S.-based companies with Sudan and most Sudanese parties. This change in the applicable law resulted in an incremental increase in transactions by the Company related to Sudan. Although the U.S. State Department's designation of Sudan as a State Sponsor of Terrorism and certain export and re-export licensing requirements remain in force, the Cummins Legal Function carefully reviewed Sudan-related transactions to ensure that these activities complied with all applicable U.S. law and with the Company's own policy.

Sales of Cummins products to Sudan are negligible. During the Response Period we identified three transactions with an end destination of Sudan for a total of approximately $160,000.

As explained above, each transaction was reviewed in accordance with Company policy and found to be in compliance with all applicable economic sanctions and export control laws.

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Please also discuss the materiality of any contacts, in quantitative terms and in terms of qualitative factors that a reasonable investor would deem important in making an investment decision. Tell us the approximate dollar amounts of any revenues, assets and liabilities associated with Syria and Sudan for the last three fiscal years and the subsequent interim period.

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Address the potential impact of the investor sentiment evidenced by divestment and similar initiatives that have been directed toward companies with operations associated with U.S.-designated state sponsors of terrorism.

Combined Company sales to Syria and Sudan constituted approximately 0.0004% of the Company's sales during the Response Period. Cummins does not consider this amount of business to be material to a reasonable investor.

Additionally, Cummins does not believe that its limited business contacts with these countries would be an issue of concern to a reasonable investor when making investment decisions. Cummins devotes significant resources to ensure that all employees are aware of the Company's expectations with respect to ethical business practices, and that all sales comply with applicable U.S.

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economic sanctions and export control laws. Cummins believes that the Company's policy and demonstrated commitment to compliance with applicable law would reassure the reasonable investor about its sales, limit the prospects of any reputational harm, and mitigate the potential negative impact on share value.

United States Securities and Exchange Commission

Division of Corporation Finance

The Company is familiar with the concerns expressed by members of the investment community regarding business with sanctioned and other restricted countries, and has discussed these concerns with investors on the occasions when they are raised. The Company will continue to do so.

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We located a 2016 report that the Wanshan Special Vehicle Company series of WS51200 vehicles in North Korea carry and erect missiles, and are powered by a Cummins K19 engine built by the Chongqing Cummins joint venture. The report states that the vehicles originally may have been sold to North Korea for civilian purposes. North Korea is designated by the State Department as a state sponsor of terrorism.

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Please provide the same information requested in the above comment about any direct or indirect contacts with North Korea. Also, address the potential for reputational harm from Cummins’ engines being used in North Korea for military purposes.

Cummins Export Control Policy and applicable U.S. law economic sanctions and export control laws strictly prohibit the company, its employees, and controlled entities from engaging in any commercial or financial transactions in North Korea or with North Korean parties. We are not aware of any direct or indirect business contacts with North Korea by Cummins or any of its controlled entities during the Response Period. Cummins maintains policies, procedures, and internal controls designed to identify and prevent such transactions before they occur.

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Like the Syria and Sudan policies described in our response to the question above, these measures are an integral part of Cummins' comprehensive, risk-based approach to international trade compliance and reflect our company's commitment to adherence with all applicable U.S. laws.

Cummins is familiar with past media reports indicating that North Korea may have obtained certain Chinese-origin vehicles containing Cummins engines. In 2012, Cummins retained outside legal counsel to conduct an independent internal investigation into the facts appearing in these media reports. That internal investigation found that Cummins sold several K19 engines to a commercial customer in China for exclusively civilian applications. There was also no evidence demonstrating that any Cummins products were installed in Chinese vehicles intended for re-export to North Korea. To the extent that there was any information regarding potential export diversion, it appears in media reports speculating that the Chinese company that originally purchased these Chinese-origin commercial vehicles may have sold them to North Korea in an unrelated transaction at a later date.

Cummins subsequently filed a self-disclosure with BIS reporting these findings. Cummins cooperated fully with the U.S. Department of Commerce and other U.S. Government agencies in this matter, including by providing them with all relevant information and documentation concerning this matter. There have been no further inquiries from BIS or other federal enforcement agencies regarding these issues, and the statute of limitations period on any potential economic sanctions or export control enforcement actions has now expired. Against this backdrop, we do not believe that there is any risk of reputational or other potential harm to Cummins resulting from this 2012 inquiry that would be relevant to our investors during the Response Period.

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