Mail Stop 4628

                                                             December 20, 2018

Via E-mail
Richard H. Fearon
Principal Financial Officer
Eaton Corporation plc
Eaton House, 30 Pembroke Road
Dublin 4, Ireland D04 Y0C2

       Re:     Eaton Corporation plc
               Form 10-K for the Fiscal Year Ended December 31, 2017
               Filed February 28, 2018
               File No. 0-54863

Dear Mr. Fearon:

        We have limited our review of your filing to your contacts with
countries that have been
identified as state sponsors of terrorism, and we have the following comments.
Our review with
respect to this issue does not preclude further review by the Assistant
Director group with respect
to other issues. In our comments, we 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.

General

   1. In your letter to us dated January 22, 2016, you discussed contacts with
Syria. The
      EMEA Electrical Sales Representatives section of Cooper Industries'
website provides
      contact information for Syria, and the Sales Contacts-Africa, Middle East
& Central Asia
      section of your website provides contact information in Morocco for
Sudan. As you
      know, Syria and Sudan are designated by the State Department as state
sponsors of
      terrorism and are subject to U.S. sanctions and/or export controls. Your
Form 10-K does
      not provide disclosure about those countries. Please describe to us the
nature and extent
      of any past, current, and anticipated contacts with Syria since the 2016
letter, and with
      Sudan, including with their governments, whether through subsidiaries,
distributors,
      resellers, affiliates, or other direct or indirect arrangements. In this
regard, we note that
 Richard H. Fearon
Eaton Corporation plc
December 20, 2018
Page 2

         your joint venture partner Cummins discussed contacts with Syria and
Sudan in
         correspondence submitted to us in May, and your customer Emirates
flies to Sudan.

      2. Please also discuss the materiality of any contacts with Syria and
Sudan, in quantitative
         terms and in terms of qualitative factors that a reasonable investor
would deem important
         in making an investment decision. Tell us the approximate dollar
amounts of any
         revenues, assets and liabilities associated with Syria and Sudan for
the last three fiscal
         years and the subsequent interim period. Please address the potential
impact of the
         investor sentiment evidenced by divestment and similar initiatives
that have been directed
         toward companies that have operations associated with state sponsors
of terrorism. For
         example, the State of Michigan Retirement Systems' website reports
that it divested from
         Eaton Corp. plc on July 18, 2017 because of business operations in
Iran, a country also
         designated as a state sponsor of terrorism. Finally, tell us whether
any contacts involve
         dual use products and, if so, the nature of the dual uses.

        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 Jennifer Hardy, Special Counsel, at (202) 551-3767 or
me at (202) 551-
3470 if you have any questions about the comments or our review.

                                                             Sincerely,

                                                             /s/ Cecilia Blye

                                                             Cecilia Blye,
Chief
                                                             Office of Global
Security Risk

cc:      Lizbeth L. Wright
         Eaton Corporation plc

         Amanda Ravitz
         Assistant Director