August 9, 2019

Gregory J. Hayes
Chairman, President and Chief Executive Officer
United Technologies Corporation
10 Farm Springs Road
Farmington, CT 06032

       Re: United Technologies Corporation
           Registration Statement on Form S-4
           Filed July 17, 2019
           File No. 333-232696

Dear Mr. Hayes:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 amending your registration statement
and providing the
requested information. 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 any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form S-4 filed July 17, 2019

General

1.     We note that the forum selection provision in your amended and restated
bylaws will
       identify a state court located within the State of Delaware (or, if no
state court located
       within the State of Delaware has jurisdiction, the federal district
court for the District of
       Delaware) as the exclusive forum for certain litigation, including any
"derivative action."
       Please disclose whether this provision applies to actions arising under
the Securities Act
       or Exchange Act. If so, please also provide risk factor disclosure
describing any risks to
       investors, and state that there is uncertainty as to whether a court
would enforce such
       provision. If the provision applies to Securities Act claims, please
also state that investors
       cannot waive compliance with the federal securities laws and the rules
and regulations
       thereunder. In that regard, we note that Section 22 of the Securities
Act creates concurrent
 Gregory J. Hayes
United Technologies Corporation
August 9, 2019
Page 2
         jurisdiction for federal and state courts over all suits brought to
enforce any duty or
         liability created by the Securities Act or the rules and regulations
thereunder.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

        You may contact Patrick Kuhn at 202-551-3308 or Lyn Shenk, Accounting
Branch Chief,
at 202-551-3380 if you have questions regarding comments on the financial
statements and
related matters. Please contact John Dana Brown at 202-551-3859 or Laura
Nicholson, Special
Counsel, at 202-551-3584 with any other questions.



FirstName LastNameGregory J. Hayes                              Sincerely,
Comapany NameUnited Technologies Corporation
                                                                Division of
Corporation Finance
August 9, 2019 Page 2                                           Office of
Transportation and Leisure
FirstName LastName