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LADISH CO., INC.

April 13, 2005

Filed via EDGAR

United States Securities
& Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0510

Attention:
Mr.
John Cash
Accounting Branch Chief

Re:
Ladish
Co., Inc. Form 10-K for the year ended December 31, 2004
Form 10-K/A for the year ended
December 31, 2004
File No. 000-23539

Dear Mr. Cash:

This letter is in response to your
April 8, 2005 correspondence wherein you raised three issues with respect to the Form 10-K
and Form 10-K/A filed by Ladish Co., Inc. (“Ladish”) for the year ended December
31, 2004. The following supplemental information is intended to address the questions
raised in the like, designated sections of your letter.

FORM 10-K FOR THE
YEAR ENDED DECEMBER 31, 2004

Management’s
Discussion and Analysis

Critical Accounting
Policies – Pensions, page 15

1.
The
principal factor utilized by Ladish when selecting a long-term rate of           return
on pension plan assets for its defined benefit pension plans is the           actual
long-term return Ladish has experienced on its pension plan assets.           Ladish then
typically selects a rate of return which is somewhat less that its           actual
experience. Given the long term nature of both the liability and the           investment
philosophy for the pension plan assets, Ladish has chosen to target           the ten
(10) year actual rate of return and use an assumed rate somewhat less           than the
actual return. As of December 31, 2004, Ladish had experienced a 10.58%           annual
rate of return on pension plan assets over the preceding ten (10) year           period.
Thus, the 9.25% assumed rate of return for pension plan assets for           actuarial
purposes is consistent with Ladish’s long standing approach to           this issue.

United States Securities
& Exchange Commission
April 13, 2005
Page 2

Financial Statements

Note 10 –
Commitments and Contingencies, page F-18

2.
In
addition to the supplemental information provided below on the asbestos
          litigation, Ladish will begin including a quarterly update in the notes to the consolidated
          financial statements beginning with the Form 10-Q for the first quarter of
          2005 and will include in future annual financial statements this disclosure
          regarding asbestos litigation in the notes to the consolidated financial
          statements.

With
respect to the cases which have been dismissed, all but one case were dismissed on
jurisdictional or procedural grounds without any payments to the plaintiffs. The one case
which was settled for an immaterial sum was funded entirely by Ladish’s liability
insurance carriers. The settlement is subject to a confidentiality agreement.

Ladish
has not accrued any amount for the remaining asbestos cases because (i) Ladish never
manufactured or processed asbestos and its only exposure to asbestos involves products
purchased from third parties; (ii) Ladish’s liability insurance carriers have assumed
the defense of the asbestos litigation; and (iii) following recent decisions of the
Mississippi Supreme Court, the number of plaintiffs in the remaining cases continues to
decline at an accelerated pace. Ladish does not believe the remaining asbestos cases will
have a material impact on its financial statements.

FORM 10-K/A FOR THE
YEAR ENDED DECEMBER 31, 2005

General

3.
An
Amendment No. 2 to Form 10-K/A will be filed as soon as directors' signatures can be
          collected. This Amendment will include Item 15, Exhibits and Financial
Statement           Schedules in its entirety as well as Section 302 certifications.

We trust you will find the foregoing
answers responsive to the issues raised in your letter. Should you have any questions do
not hesitate to contact me at (414) 747-2935.

Ladish understands it is responsible
for the adequacy and accuracy of the information disclosed in filings, Ladish understands
staff comments and changes made in response thereto do not foreclose the Commission from
taking any action and Ladish will not assert staff comments as a defense in any proceeding
initiated by the Securities and Exchange Commission.

Sincerely,

/s/ Wayne E. Larsen