The Nieuport 28C-1 was the latest, in an on-going evolution of the Nieuport design philosophy. The changes made in the design were intended to improve/correct problems, which had occurred in previous designs. The Nieuport effort was, however, unsuccessful as the French Aviation Militaire, through its Section Technical Aeronautiqué, opted to select as its standardized chasse aircraft the Spad XIII. At the time of the arrival of the A.E.F. Air Service in France there was insufficient Spad production to allocate this aircraft to the Americans. It was therefore decided to provide the Nieuport 28C-1 to the Americans until such time as the Spad XIII became available. The A.E.F. eventually took possession of 297 Nieuport 28 aircraft.

Initial assignment of the machines was to the First Pursuit Group (the 27th, 94th, 95th, and 147th Aero Squadrons). Either the 150 hp Gnôme Monosoupape 4-N engine or the 160-170 hp Gnôme 9-N engine powered production machines. The aircraft was armed with two Vickers .303 machine guns—one mounted outboard of the left center-section strut and one on top of the fuselage to the left of the center-line. Some American squadrons used the American Marlin machine gun in lieu of the Vickers gun. For balloon attacks the Vickers guns would be replaced by a single 11 mm Vickers gun, armed with incendiary ammunition, and mounted in the inboard location.

The aircraft was not well received by the Americans because of its inability to effectively engage the Fokker D.VII. It also was both prone to shedding the fabric on the leading edge of the top wing in a steep dive and the engine had a tendency to catch fire. The aircraft served with the A.E.F. for about four months before being replaced by the Spad X.III.