SecProbe.io

July 8, 2013

Via E -mail
Mr. Dale G. Reid
Executive Vice President , Finance  and Chief Financial Officer
Allegheny Technologies Inc orporat ed
1000 Six PPG Place
Pittsburgh, PA 15222 -5479

Re: Allegheny Technologies  Incorporat ed
 Form 10-K
Filed February 28 , 2013
File No. 1-12001

Dear Mr. Reid :

We have reviewed your filing  and have the following comments.  We have limited our
review to only your financial statements and related disclosures and do not intend to expand our
review to other portions of your document.   In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business d ays by providing the requested
information, or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information y ou provide in response to these  comments, we may
have  additional comments.

Form 10 -K for the year ended December 31, 2012

Backlog, Seasonality and Cyclicality, page 6

1. Please explain to us and revise future filings as appropriate to disclose why there is no
backlog attributable to the Engineered Products segment.

Management’s Discussion and Analysis, page 16

2. We note the $8.8 million after -tax charge for asset write -down associated with
consolidating your iron casting facilities in your Engineer ed Products business segment.
Given this amount was material to fourth quarter 2012 operating results, please tell us
your consideration for providing a discussion of the performance of these operations,
including trends, potential impacts on future operat ions, your method for grouping the

Mr. Dale G. Reid
Allegheny Technologies Inc orporat ed
July 8, 2013
Page 2

 related long -lived assets, and your assessment of potential impairment of related assets.
Tell us whether you provided forewarning disclosure regarding these operations in
periodic reports prior to incurring the charge.

Note 15. Financial Information for Subsidiary and Guarantor Parent, page 72

3. Please tell us how you have complied with Rules 3 -10(i)(1) and 10 -01(a)(4) of
Regulation S -X in presenting your condensed statements of cash flows for the years
ended December 31 , 2010 through 2012.  Revise future filings accordingly, beginning
with your June 30, 2013 Form 10 -Q.

Form 10 -Q for the period ended March 31, 2013

Management’s Discussion and Analysis, page 22

4. Please revise future filings to quantify the extent to which increases/decreases in volume,
prices, the introduction of new products, and inflation impacts of raw materials
contributed to the changes in net sales and gross profit margin and/or segment operating
profit.  In addition, please quantify the impact of other factors you identify that
contributed to fluctuations in line items included in income from continuing operations.
Please refer to Items 303(A)(3)(i) and 303(A)(3)(iii) of Regulation S -X and Sections
501.12.b.3. and 501.12.b.4. of the Financial R eporting Codification for guidance.

5. We note that your gross margin has decreased over the five quarters ended March 31,
2013. Please revise future filings to expand your discussion of gross margin and/or
segment operating profit to provide a detailed and appropriately quantified analysis of the
factors contributing to gross margin and/or segment operating profit declines that
provides investors an understanding through the eyes of management of the impact of
changes in these factors and plans to manage the m.

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 statement from t he 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 res pect to the filing; and

Mr. Dale G. Reid
Allegheny Technologies Inc orporat ed
July 8, 2013
Page 3

  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.

You may contact Jenn Do at (202) 551-3743 , or me at (202) 551-3355  if you have
questions regarding comments on the financial statements and related matters.

Sincerely,

 /s/ Terence O ’Brien

Terence O’Brien
Branch Chief