SecProbe.io

Mail Stop 3561
August  19, 201 5

Joseph P. Bellino
Vice President, Treasurer and Chief Financial Officer
Ducommun Incorporated
23301  Wilmington Avenue
Carson, CA 90745

Re: Ducommun Incorporated
 Form 10-K for Fiscal Y ear Ended December  31, 2014
Filed April  10, 201 5
File No. 001-08174

Dear Mr. Bellino :

We have reviewed your filing an d have the following comment s.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these  comment s within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not belie ve our
comment s apply  to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comment s, we may
have  additional comments.

Management’s Discussion and Analysis, page 26

1. While we note t he disclosure in the second paragraph of the “Overview” section, please
expand your discussion to enhance an investor’s understanding of your business, and provide
further insight regarding material opportunities, challenges and risks on which you are
focused in both the short and long term, as well as the steps you are taking to address
them.   See Section III.A of SEC Release 33 -8350 (Nov. 29, 2003).   For example, if
applicable, please expand to discuss:

 your efforts in penetrating the engine markets and any material long -term supply
agreements you have recently finalized;
 your efforts to target major strategic industrial customers;
 your actions in addressing the level of manufacturing expenses and pursuing cost
reduction activities and supply chain initi atives aimed at improving operating
performance;

Joseph P. Bellino
Ducommun Incorporated
August 19 , 2015
Page 2

  the effect of declining military programs and the sun setting of certain platforms, such as
the wind down of the Boeing C -17 program for which you made your last shipments in
the fourth quarter and reduction s in the Apache main rotor which has seen reduced
customer requirements;
 your expectations as to revenue trends within the military and space markets; and
 your 50% organic growth in your commercial aerospace business over the past five years.

Results of  Operations, page 29

2. We note that cost of sales is material to your results and varies between periods as a
percentage of revenues but you do not provide a direct discussion and analysis of this line
item.  Please revise your disclosure to provide a direct comparative discussion and analysis
of these costs in addition to your current disclosure that is in the context of gross profit .  In
doing so, please disclose the material components of which these costs consist.  Your
disclosure should q uantify and analyze the impact of each (and not netted) significant
component of cost of sales that caused this line item to materially vary (or not vary when
expected to)  between comparative periods, with explanation of the associated underlying
reasons.  In this regard, we believe materiality should be assessed in relation to operating
income.  This disclosure should be presented in a manner to allow investors to discern the
relative contribution of each component cited to the total change in cost of sale s (i.e.,
quantify the component).  In addition, the impacts of material variances in differing
components of cost of sales that offset each other should be separately disclosed, quantified,
and discussed (and not netted).  Please revise your disclosure as appropriate.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange 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.

 In responding to our comments, please provide  a written stateme nt from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action  with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Joseph P. Bellino
Ducommun Incorporated
August 19 , 2015
Page 3

 You may contact Patrick Kuhn  at (202) 551 -3308  or Doug Jones at (202) 551 -3309  if you
have questions regarding comments on the financial statements and related matters.   Please
contact Julia  Griffith  at (202) 551-3267 or Anne Nguyen  Parker at (202) 551-3611 concerning
other matters.  You may also call me at (202) 551 -3380.

Sincerely,

 /s/ Lyn Shenk

Lyn Shenk
Branch Chief
Office of Transportation and Leisure