SecProbe.io

August 22 , 2013

Via E -mail
Mr. Patrick DeCourcy
Interim  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. DeCourcy :

We have re ad your response dated August 13 , 2013 and have the following comment s.

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

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

Form 10 -Q for the period ended June 30, 2013

Note 11. Financial Information for Subsidiary and Guarantor Parent, page 16

1. We note the revision you have made to the condensed statements of cash flows on pages
18 and 20 in response to comment 3 in our letter dated July 8, 2013. In the financing
activities sections, you present a line item for “Net receipts/(payments) on intercompany
activity.”  Please tell us the types of transa ctions that are generating these intercompany
receipts and payments and explain how you determined each type of transaction was
appropriately labeled as a financing activity.  Refer to ASC 230 -10-45.  Also, please tell
us why there are no intercompany asse ts and intercompany liabilities shown as separate
line items on the condensed balance sheets.

Management’s Discussion and Analysis, page 24

2. We have read your response to comment 1 in our letter dated August 1, 2013. We note,
among other things, the conti nued declines in your operating and gross margins during

Mr. Patrick D eCourcy
Allegheny Technologies Inc orporat ed
August 22, 2013
Page 2

 the second quarter, and the remarks from the second quarter earnings release and earnings
call transcript regarding the uncertain global environment that have had a significant
negative effect on dem and and raw material pricing. Please revise future filings to
provide a more detailed discussion of the macroeconomic factors that have currently had
a material adverse impact on your financial results, providing quantitative analysis where
appropriate. Ma nagement’s discussion and analysis should provide the reader with an
understanding of the challenges currently facing the global steel industry, the impact on
your operations, your strengths and vulnerabilities, and your expectations for potential
future e ffects to your operations and liquidity, as seen through the eyes of management.
For example, on page 27 you state that you continue to believe that “market conditions
remain favorable for long -term secular growth from our key markets of aerospace, oil and
gas/chemical process industry, electrical energy, and medical” but the foregoing should
also be accompanied by insight that analyzes the underlying forces that are presently, and
for the short -term, making market conditions unfavorable.

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