August 9, 2024

Matthew F. Pine
President and Chief Executive Officer
Xylem Inc.
301 Water Street SE
Washington, DC 20003

       Re: Xylem Inc.
           Definitive Proxy Statement on Schedule 14A
           Filed April 2, 2024
           File No. 001-35229
Dear Matthew F. Pine:

      We have limited our review of your most recent definitive proxy statement
to those issues
we have addressed in our comment(s).

       Please respond to this letter by providing the requested information
and/or confirming that
you will revise your future proxy disclosures in accordance with the topics
discussed below. If
you do not believe a comment applies to your facts and circumstances, please
tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Definitive Proxy Statement on Schedule 14A
Pay Versus Performance, page 65

1.     We note that you have included Revenue as your Company-Selected Measure
pursuant to
       Item 402(v)(2)(vi) of Regulation S-K. Please include your
Company-Selected Measure in
       the Tabular List provided pursuant to Item 402(v)(6) of Regulation S-K.
In that regard, we
       note that you included    Organic Revenue    in your Tabular List, but
not Revenue.
 August 9, 2024
Page 2

        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.

       Please contact Laura Nicholson at 202-551-3584 or Amanda Ravitz at
202-551-3412 with
any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Disclosure Review
Program