November 2, 2018 Kenneth L. Bedingfield Chief Financial Officer Northrop Grumman Corporation 2980 Fairview Park Drive Falls Church, Virginia 22042 Re: Northrop Grumman Corporation Form 10-K for the Fiscal Year Ended December 31, 2017 Filed January 29, 2018 Form 10-Q for the Quarterly Period Ended September 30, 2018 Filed October 24, 2018 File No. 001-16411 Dear Mr. Bedingfield: We have limited our review of your filing to the financial statements and related disclosures 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 to these comments, we may have additional comments. Form 10-Q for the Quarterly Period Ended September 30, 2018 Note 1. Basis of Presentation Revenue Recognition, page 5 1. Please tell us if you recognized any impairment losses on receivables or contract assets arising from your contracts with customers. If material, please disclose in the notes to the financial statements the information pursuant to ASC 606-10-50-4b. 2. We note for certain of your contracts there is a change in the number of performance obligations under ASC 606 which altered the timing of revenue and margin recognition. Please elaborate for us the nature of such contracts and the changes that resulted from the Kenneth L. Bedingfield Northrop Grumman Corporation November 2, 2018 Page 2 adoption of ASC 606. In closing, 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. You may contact Beverly Singleton at (202) 551-3328 or Jean Yu at (202) 551-3305 with any questions. FirstName LastNameKenneth L. Bedingfield Sincerely, Comapany NameNorthrop Grumman Corporation Division of Corporation Finance November 2, 2018 Page 2 Office of Transportation and Leisure FirstName LastName