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March 10, 2011

Ms. Pamela A. Long

Assistant Director

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

    Re:

    Allegheny Technologies Incorporated

Amendment No. 2 to the Registration Statement on Form S-4

Filed February 22, 2011

File No. 333-171426

Form 10-K for the Fiscal Year Ended December 31, 2010

Filed February 28, 2011

File No. 001-12001

Dear Ms. Long:

     We are providing this letter in response to the comments of the staff of the Securities and
Exchange Commission (the “Staff”) contained in your letter dated March 4, 2011 regarding Amendment
No. 2 to the Registration Statement on Form S-4 filed by Allegheny Technologies Incorporated
(“ATI”) on February 22, 2011 (File No. 333-171426) (the “Form S-4”). Set forth below are the
Staff’s comments and our responses. We also call to the Staff’s attention that ATI has filed
Amendment No. 3 to the Form S-4 on the date of this letter.

     Pursuant to Rule 418 of the Securities Act of 1933, as amended (the “Securities Act”), the
Company requests that, upon completion of this review, the Staff return to us all supplemental
materials provided in connection with this review.

Amendment No. 2 to the Registration Statement on Form S-4

Interest of Ladish’s Directors and Officers in the Merger, page 3

COMMENT NO. 1:

Please quantify the potential unissued shares eligible for issuance under the Ladish Co., Inc. 2010
Restricted Stock Unit Plan.

Ms. Pamela A. Long

Securities and Exchange Commission

March 10, 2011

Page 2

RESPONSE:

     We have revised our disclosures on pages 3 and 52 of Amendment No. 3 to the Form S-4 to
quantify the potential number of additional restricted stock units
issued under the Ladish Co, Inc.
2010 Restricted Stock Unit Plan that may be received by executive officers and
directors of Ladish Co, Inc. (“Ladish”).

Where You Can Find More Information, page 97

COMMENT NO. 2:

Please revise this section to incorporate by reference the Form 8-K and Form 10-K each filed by
Allegheny on February 28, 2011 and the Form 8-K filed by Ladish on February 10, 2011. See Question
123.05 of the Compliance and Disclosure Interpretations for Securities Act Forms.

RESPONSE:

     We have revised this section in Amendment No. 3 to the Form S-4 to incorporate by reference
the applicable filings made by us or Ladish since the filing of Amendment No. 2 to the Form S-4,
including the Current Report on Form 8-K and the Annual Report on Form 10-K (the “ATI Form 10-K”)
filed by ATI on February 28, 2011. We note to the Staff that the Current Report on Form 8-K filed
by Ladish on February 10, 2011 (the “Ladish Form 8-K”) solely included disclosure under Item 2.02
and an exhibit relating to Item 2.02 which was furnished by Ladish under Item 9.01. Under General
Instruction B.2. of Form 8-K, none of the information contained in the Ladish Form 8-K is deemed to
be “filed” for purposes of Section 18 of the Securities Exchange Act of 1934, as amended (the
“Exchange Act”), or otherwise subject to the liabilities of that section because Ladish has not
specifically stated that the information is to be considered “filed” under the Exchange Act or
incorporated by reference into a filing under the Securities Act or the Exchange Act. In order to
treat the Ladish Form 8-K in a manner consistent with the Current Reports on Form 8-K filed by ATI
on January 26, 2011, which were not subject to the Staff’s Comment but similarly contained
disclosures solely under Item 2.02 and respective exhibits relating to Item 2.02, we have not
included a reference to the Ladish Form 8-K in this section.

COMMENT NO. 3:

We note that Allegheny’s Form 10-K for the fiscal year ending December 31, 2010 was filed on
February 28, 2011, and that the Form 10-K incorporates by reference the Part III information from
the definitive proxy statement, which Allegheny has not yet filed. In order to have a complete
Section 10(a) prospectus, you must either file the definitive proxy statement before the Form S-4
is declared effective or include the Part III information in an amended Form 10-K. We further note
that, based on conversations with counsel, Ladish intends to file its Form10-K in approximately two
weeks. Please note, the Part III information for Ladish must also be on file

Ms. Pamela A. Long

Securities and Exchange Commission

March 10, 2011

Page 3

before the Form S-4 can be declared effective. See generally Question 123.01 of the Compliance and
Disclosure Interpretations for Securities Act Forms.

RESPONSE:

     We acknowledge the Staff’s comment. We filed ATI’s definitive proxy statement containing the
Part III information that is incorporated by reference into the ATI Form 10-K on March 9, 2011.
Ladish filed its Annual Report on Form 10-K for its fiscal year ended December 31, 2010, including
the Part III information, on March 9, 2011.

Exhibit 99.2

COMMENT NO. 4:

We note that Baird continues to state that its consent applies only to the current proxy statement
included in the registration statement, and not to any amendments or supplements thereto. Please
be advised that in order for the Form S-4 to be declared effective, Baird will have to file an
updated consent or remove such qualifying language.

RESPONSE:

     We continue to acknowledge this comment of the Staff. We have filed an updated consent of
Robert W. Baird & Co, Incorporated (“Baird”) with Amendment No. 3 to the Form S-4 and similarly
will file an updated consent of Baird with any subsequent amendment to the Form S-4.

Form 10-K for the Fiscal Year Ended December 31, 2010

Legal Proceedings, page 14

COMMENT NO. 5:

We note your statement that while you believe that the disposition of any pending legal matter is
not likely to have a material adverse effect on your financial condition or liquidity, the
resolution in any reporting period of one or more of the legal matters could have a material
adverse effect on your results of operations for that period. For any pending legal matter that
you believe could have a material adverse effect on your results of operations, please provide the
disclosure required by Item 103 of Regulation S-K and ASC 450-20-50. Please supplementally provide
us with draft disclosure showing how you will present this information in future filings.

RESPONSE:

     We acknowledge the Staff’s comment and advise the Staff that there are no pending legal
matters that we believe could have a material adverse effect on our results of operations.

Ms. Pamela A. Long

Securities and Exchange Commission

March 10, 2011

Page 4

COMMENT NO. 6:

We note your disclosure regarding the lawsuit filed by the EPA and the California Department of
Toxic Substance Control filed in the United States District Court for the Central District of
California on January 13, 2011. With a view toward future filings, please supplementally advise us
as to whether you reasonably believe that such proceeding will result in no monetary sanctions or
monetary sanctions of less than $100,000. To the extent you reasonably believe that monetary
sanctions may be more than $100,000, please provide the information required by Item 103 of
Regulation S-K, including relief sought. See Instruction 5.C. to Item 103 of Regulation
S-K.

RESPONSE:

     We advise the Staff that we do not reasonably believe that the referenced proceeding will
result in monetary sanctions because it is a cost recovery action without civil penalties being
sought. We, however, refer the Staff to the first paragraph under Item 3, Legal Proceedings, in
the ATI Form 10-K, in which, in accordance with Item 103 of Regulation S-K, we included the name of
the court or agency in which the proceeding is pending (the United States District Court for the
Central District of California), the date instituted (January 13, 2011), the principal parties
thereto (the United States Environmental Protection Agency, the California Department of Toxic
Substance Control, a subsidiary of ATI and the remaining potentially responsible parties), a
description of the factual basis alleged to underlie the proceeding (a description of the
background involving the 2003 Unilateral Administrative Order issued to ATI and the other
potentially responsible parties for the South El Monte Operable Unit of the San Gabriel Valley
(California) Superfund Site) and the relief sought (recovery of past costs and future response
costs under CERCLA).

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 18

Results of Operations, page 21

COMMENT NO. 7:

We note that there was a sizable increase in the percent of total revenue contributed by your
Flat-Rolled Products segment from 2009 to 2010, while there was a corresponding decrease in the
percent of total revenue contributed by your High Performance Metal segment, despite the fact that
revenue increased in both segments. In future filings, please provide disclosure identifying the
underlying reasons for such changes in the contribution of your segments to total revenue.

Ms. Pamela A. Long

Securities and Exchange Commission

March 10, 2011

Page 5

RESPONSE:

     We acknowledge the Staff’s comment and will revise our disclosures in future filings in
accordance with the Staff’s comment.

COMMENT NO. 8:

In future filings, please revise your analysis to quantify the specific factors that contributed to
the fluctuations in your line items from period-to-period, and also provide the reasons underlying
such fluctuations where the reasons are material and determinable. For example, your discussion of
the High Performance Metals segment on page 21 cites increased demand from the commercial aerospace
jet engine market and medical market, as well as decreased demand from the chemical processing
market and nuclear energy market, as all contributing to the change in sales from 2009 to 2010.
However, you do not quantify the amount contributed by each of these markets to the change in
sales, and do not discuss the reasons underlying such changes with the exception of the aerospace
market. Further, you state that volumes increased for certain of your products, while selling
prices decreased, but do not provide analysis regarding the reasons underlying the changes in
volume and price, including how such changes contributed to the year-over-year increase in sales.
For example, without further disclosure, it is unclear why there was a more competitive pricing
environment in 2010, and how this specifically affected base selling prices. Please supplementally
provide us with draft disclosure for your year-over-year segment discussion showing how you will
present this information in future filings. See Item 303 of Regulation S-K and SEC Release
No. 33-8350.

RESPONSE:

     We acknowledge the Staff’s comment and will revise our disclosures in future filings in
accordance with the Staff’s comment. As requested by the Staff, we supplementally are providing
draft disclosure to demonstrate how we will expand our discussion in future filings. We call to
the Staff’s attention that we are enhancing our discussion to the extent that the reasons for
fluctuations are material and determinable. In certain of our end markets, such as commercial
aerospace, the end customers for our products generally have significant order backlogs and longer
order fulfillment cycles, affording us greater clarity into the factors in the supply chain that
are impacting changes in demand, which in turn impacts our pricing.
However, customers purchasing our stainless steel commodity products
generally are service centers which, in turn, distribute products to
end users in various markets. As a result, we do not generally have
reliable insight into factors influencing demand for those products
by particular categories of end users. In addition, in many of our end
markets, such as chemical processing, which typically is driven primarily by large project
business, and medical, which generally has significantly shorter order fulfillment cycles, the
underlying rationale for fluctuations often is driven by a number of factors, such as general
macroeconomic conditions and specific customer and competitive factors that are prevalent at a
given time. While market demand has an influence on selling prices for most of our products, we
compete with a number of global competitors which frequently establish product selling prices based
upon factors known only to them. In instances such as these, the relative significance of any
single factor or combination of factors that drive demand for our

Ms. Pamela A. Long

Securities and Exchange Commission

March 10, 2011

Page 6

products or impact pricing environments, or the underlying reasons for actions taken by our
competitors in particular markets, may not be determinable based on information available to us.

Certifications

COMMENT NO. 9:

We note that in paragraph three you refer to “annual report” rather than “report” and that you have
deleted the “(s)” from “certifying officer(s)” in paragraphs four and five. In future filings,
please file the certifications in exactly the form set forth in Item 601(b)(31) of Regulation S-K.

RESPONSE:

     We acknowledge the Staff’s comment and will file the certifications in future filings in
exactly the form set forth in Item 601(b)(31) of Regulation S-K.

* * *

     ATI acknowledges that:

    •

    should the Securities and Exchange Commission (the “Commission”) or the staff,
acting pursuant to delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the filing;

    •

    the action of the Commission or the staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the Company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and

    •

    the Company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Ms. Pamela A. Long

Securities and Exchange Commission

March 10, 2011

Page 7

     Thank you for your consideration. If you require any additional information on these issues,
or if I can provide you with any other information that will facilitate your continued review of
the Form S-4, please contact me at 412-394-2836 at your earliest convenience.

    Sincerely,

ALLEGHENY TECHNOLOGIES INCORPORATED

    By:
    /s/ Jon D. Walton

    Jon D. Walton

    Executive Vice President, Human Resources,
Chief Legal and Compliance Officer
and Corporate Secretary