SecProbe.io

July 22, 2010

Mr. James S. Heiser Vice President, General Counsel, and Secretary
Ducommun Incorporated 23301 Wilmington Avenue Carson, CA 90745-6209
Re: Ducommun Incorporated
  Amendment No. 1 to Registra tion Statement on Form S-3
Filed July 7, 2010
  File No. 333-167021

Dear Mr. Heiser:
 We have reviewed your responses to the comments in our letter dated June 8, 2010 and
have the following additional comments.    Risk Factors, page 1

1. We note your response to our prior comment number 1; however, the first paragraph
under this heading continues to refer to risks which may be described in sections of the
relevant documents other than the risk factors section.  Please revise to remove references
to such other section, since you must describe all known material risks in the risk factors
section.

Exhibit 5.1

2. Please have counsel revise paragraph (vii) on page 3 and paragraph A on page 8 to
indicate that the opinion speaks as of the date of the eff ectiveness of the registration
statement.  Alternatively, confirm that couns el will refile the opini on dated the date of
effectiveness.

3. We note your response to previous comment 2, and we note that counsel’s opinion is
limited to the laws of the State of New Yo rk, the Delaware General Corporation Law,
and the California Corporations Code.  We al so note that the subsidiary guarantors are
incorporated or organized in Arizona, Alabama, California, Delaware, or New York.
Counsel is entitled to rely upon another counsel ’s opinion to the extent  necessary.  Please
have counsel revise its opinion letter so that it relies on the op inions filed as Exhibits 5.2
and 5.3.

James S. Heiser Ducommun Incorporated July 22, 2010 Page 2

Exhibit 5.2

4. Please have counsel revise paragraph (i) on page 2 and the third sentence of the
penultimate paragraph on page 2 to indicate th at the opinion speaks as  of the date of the
effectiveness of the registration statement.  A lternatively, confirm that counsel will refile
the opinion dated the date of effectiveness.
 Exhibit 5.3

5. Please have counsel remove the list of documents reviewed on pages 1 and 2.  Counsel may review any documents of its client it be lieves are necessary to render an opinion.
Alternatively, revise to state that counsel ha s examined all other documents as necessary
to render its opinion.

6. Please have counsel revise pa ragraph 4.2 to remove the assu mption that “the Securities
will contain typical and customary terms” as  it is not appropriate to include such a
subjective assumption in counsel’s opinion nor is  it appropriate to sh ift such a risk to
investors.

7. Please have counsel revise para graph 4.4 on page 2 to indicate that the opinion speaks as
of the date of the effectiveness of the regist ration statement.  Alternatively, confirm that
counsel will refile the opinion dated the date of effectiveness.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Please contact Sonia Bednarowski at (202) 551-3666 or me at (202) 551-3412 with any
questions.

Sincerely,
        Amanda Ravitz                                                  Branch Chief- Legal
cc: Via Facsimile: (213) 229-6196   Dhiya El-Saden, Esq.   Gibson, Dunn & Crutcher LLP