SecProbe.io

May 14, 2018
Patrick DeCourcy
Chief Financial Officer
ALLEGHENY TECHNOLOGIES INC
1000 Six PPG Place
Pittsburgh, PA. 15222
Re:ALLEGHENY TECHNOLOGIES INC
Form 10-K as of December 31, 2017
Filed February 20, 2018
File No. 001-12001
Dear Mr. DeCourcy:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  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 comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the period ended December 31, 2017
Note 2. Inventories, page 57
1.We note your disclosure that due to deflationary impacts primarily related to raw
materials, the carrying value of your inventory as valued on LIFO exceeds current
replacement cost, and as such a net realizable value (NRV) inventory reserve was
required. Based on your tabular disclosure, it appears you recorded this reserve in fiscal
year 2015. Please clarify the nature of the NRV benefit reflected in fiscal years 2016 and
2017.  If they represent reversals of previously recognized write downs, please tell us how
you considered the guidance in ASC 330-10-35-14 and SAB Topic 5.BB.
Note 16. Restructuring Charges, page 85
2.Please expand your disclosures for your restructuring actions to also provide the expected

 FirstName LastNamePatrick DeCourcy
 Comapany NameALLEGHENY TECHNOLOGIES INC
 May 14, 2018 Page 2
 FirstName LastName
Patrick DeCourcy
ALLEGHENY TECHNOLOGIES INC
May 14, 2018
Page 2
completion date, the total amount expected to be incurred by each major type of cost, and
for each reportable segment the total amount of cost expected to be incurred in connection
with the activity, the amount incurred in the period and the cumulative amount incurred to
date as required by ASC 420-10-50-1.  Please expand your MD&A to also include the
amount of the anticipated future cost savings for these activities, and whether the actual
results were in line with the anticipated cost savings. If the anticipated cost savings were
not achieved as expected or will be achieved in periods other than as expected, please
disclose the reasons for the differences, and the likely effects on future operating results
and liquidity. Please refer to SAB Topic 5:P.4 for guidance.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Ameen Hamady, Staff Accountant at (202)-551-3891, or in his absence,
Jeanne Baker  at (202)-551-3691 with any questions.
Division of Corporation Finance
Office of Manufacturing and
Construction