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                                                            February 19, 2019

David J. Endicott
Chief Executive Officer
Alcon Inc.
Rue Louis-d'Affry 6
1701 Fribourg, Switzerland

       Re: Alcon Inc.
           Amendment No. 1 to Registration Statement on Form 20-F
           Filed December 27, 2018
           File No. 001-31269

Dear Mr. Endicott:

       We have reviewed your amended filing 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 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
response.

     After reviewing your response and any amendment you may file in response
to these
comments, we may have additional comments. Unless we note otherwise, our
references to prior
comments are to comments in our December 10, 2018 letter.

Form 20-F amended December 27, 2018

Failure to comply with law..., page 50

1.     We note your response to prior comment 9. Please quantify the portion of
your business
       derived from your activities in the referenced geographical locations.
In this regard, it
       remains unclear why the extent of your business subject to the disclosed
risk is not
       material given the exclusions from the indemnification agreement with
your parent
       outlined in Section 14.2 of exhibit 4.1.
Condensed Combined Interim Financial Statements
Note 3. Selected critical accounting policies, Revenue recognition, page F-86

2.     We note from your response to comment 16 that certain of your surgical
equipment sales
       arrangements include usage-based payment terms. Please describe to us
these
 David J. Endicott
Alcon Inc.
February 19, 2019
Page 2
      arrangements in greater detail, including the types of equipment usually
involved, and
      explain to us the option under which the customer may instead elect to
make direct cash
      payments.
        You may contact Kristin Lochhead at 202-551-3664 or Brian Cascio,
Accounting Branch
Chief, at 202-551-3676 if you have questions regarding comments on the
financial statements
and related matters. Please contact Heather Percival at 202-551-3498 or Amanda
Ravitz,
Assistant Director, at 202-551-3412 with any other questions.



                                                          Sincerely,
FirstName LastNameDavid J. Endicott
                                                          Division of
Corporation Finance
Comapany NameAlcon Inc.
                                                          Office of Electronics
and Machinery
February 19, 2019 Page 2
cc:       D. Scott Bennett
FirstName LastName
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