April 13, 2020 E. Mark Rajkowski Chief Financial Officer Xylem Inc. 1 International Drive Rye Brook, NY 10573 Re: Xylem Inc. Form 10-K for the Year Ended December 31, 2019 Filed February 28, 2020 Dear Mr. Rajkowski: We have completed our review of your filings. 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. Sincerely, Division of Corporation Finance Office of Technology