SecProbe.io

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      May 31, 2005

Mr. Wayne E. Larsen
Vice President Law/Finance & Secretary
Ladish Co., Inc.
5481 S. Packard Avenue
Cudahy, Wisconsin 53110

      Re:	Ladish Co., Inc.
Form 10-K for Fiscal Year Ended December 31, 2004
		File No. 0-23539

Dear Mr. Larsen:

      We have reviewed your response letter dated April 13, 2005
and
have the following additional comment.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  After reviewing this information, we may
or
may not raise additional comments.

Management`s Discussion and Analysis, page 10

Critical Accounting Policies - Pensions, page 15

1. Reference is made to your reply to prior comment 1 and to your
discussion of pensions under critical accounting policies.  Please
provide us with additional information showing your annual rate of
return on pension plan assets for each of the ten years ended
December 31, 2004.  It appears that the actual rate of return of
each
of the two years ended December 31, 2004 was less than your
expected
return of 9.25%.  In addition, please tell us whether your actual
and
targeted asset allocation categories over the 10-year period have
remained approximately as shown by the information in Note 8,
Pensions and Postretirement Benefits.

Also, in the future, your discussion in critical accounting
policies
of pensions should provide quantitative sensitivity information
about
the impact of changes in your actuarial assumptions.

	*	*	*	*

		Please respond to this comment within 10 business days
or
tell us when you will provide us with a response.  Please provide
us
with a supplemental response letter that keys your response to our
comment.  Detailed cover letters greatly facilitate our review.
Please file your supplemental response on EDGAR as a
correspondence
file.  Please understand that we may have additional comments
after
reviewing your response to our comment.

		If you have any questions regarding this comment, please
direct them to Dale Welcome, Staff Accountant, at (202) 551-3865,
Nathan Cheney, Assistant Chief Accountant, at (202) 551-3714 or,
in
their absence, to the undersigned at (202) 551-3768.

      Sincerely,

John Cash
Accounting Branch Chief

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Mr. Wayne E. Larsen
Ladish Co., Inc.
May 31, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

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