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Correspondence

    Squire, Sanders & Dempsey L.L.P.

    2000 Huntington Center

    41 South High Street

    Columbus, Ohio  43215

Office: +1.614.365.2700

    Fax: +1.614.365.2499

October 27, 2010

Via Edgar Correspondence

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-3628

    Attention:

    Mr. Dale Welcome

Mr. John Cash

Mr. Edward M. Kelly

Mr. Andrew P. Schoeffler

      Division of Corporation Finance

    Re:

     Core Molding Technologies, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2009

Definitive Proxy Statement on Schedule 14A filed April 16, 2010

Forms 10-Q for the Fiscal Quarters Ended March 31, 2010 and June 30, 2010

File No. 001-12505

Ladies and Gentlemen:

On behalf of our client, Core Molding Technologies, Inc. (the “Company”), we are responding to
the comments of the staff (the “staff”) of the Securities and Exchange Commission (the
“Commission”) set forth in your letter dated October 13, 2010 with respect to the above-referenced
filings. To facilitate the staff’s review, this letter includes each of the staff’s comments in
italics, followed by the Company’s response to the staff’s comments.

Form 10-K
for the Fiscal Year Ended December 31, 2009

Cover Page

1. Please revise the cover page in future filings to identify your preferred stock purchase
rights as being registered under Section 12(b) of the Exchange Act. In this regard, we note the
Form 8-A filed on July 19, 2007.

Response: In response to the staff’s comment, the Company will revise the cover
page in future filings to identify its preferred stock purchase rights as being registered
under Section 12(b) of the Exchange Act of 1934, as amended (the “Exchange Act”).

Index to Exhibits, page 58

Squire, Sanders & Dempsey L.L.P.

Securities and Exchange Commission

October 27, 2010

Page 2

2. We note that you did not file on EDGAR any of the appendices to the supply agreement
identified as exhibit 10(a). We also note that the request for confidential treatment does not
appear to cover these appendices. Please advise.

Response: The Company acknowledges the staff’s comment. The Company had taken
the position with respect to this supply agreement that the appendices were not material to
an understanding of the agreement or material to an investment decision. Notwithstanding
the Company’s view that the appendices do not materially enhance an investor’s understanding
of the supply agreement and in that regard are, in the Company’s view, immaterial, the
Company will file a complete copy of the supply agreement with its next Quarterly Report on
Form 10-Q for the quarter ended September 30, 2010, inclusive of the previously omitted
appendices. The Company does anticipate filing an application for confidential treatment
for select portions of the re-filed supply agreement and appendices, pursuant to Rule 24b-2
under the Exchange Act, as the supply agreement and appendices include confidential
commercial information. Going forward the Company will, in accordance with Item 601(b)(10)
of Regulation S-K, file complete copies of all future material definitive agreements,
inclusive of exhibits, schedules, appendices or other attachments.

3. We note that you did not file on EDGAR any of the schedules to the supply agreement
identified as exhibit 10(b). We also note that the request for confidential treatment does not
appear to cover all of these schedules. Please advise.

Response: The Company acknowledges the staff’s comment. Similar to the supply
agreement identified as exhibit 10(a), the Company had taken the position with respect to
this supply agreement that the schedules were not material to an understanding of the
agreement, or material to an investment decision. As discussed in response to the staff’s
comment 16 below, this supply agreement has since expired, and is no longer in effect.
Accordingly, the Company respectfully submits that filing the immaterial omitted schedules
at this time is not necessary. These schedules are voluminous in nature and include
extensive technical data with respect to product specifications and performance. Going
forward the Company will, in accordance with Item 601(b)(10) of Regulation S-K, file
complete copies of all future material definitive agreements, inclusive of exhibits,
schedules, appendices or other attachments.

4. We note that you did not file on EDGAR all of the schedules to the credit agreement
identified as exhibit 10(d). We also note that you did not file on EGDAR the attachments to
exhibits K and L to the credit agreement. Please file your complete credit agreement, including
all schedules and exhibits, with your next periodic report or, if you wish, a current report on
Form 8-K.

Response: The Company acknowledges the staff’s comment and will file a complete
copy of its credit agreement, including all schedules, exhibits and attachments, with its
next Quarterly Report on Form 10-Q for the quarter ended September 30, 2010.

Squire, Sanders & Dempsey L.L.P.

Securities and Exchange Commission

October 27, 2010

Page 3

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of  Operations, page 19

Results of Operation, page 20

5. In future annual and quarterly filings please:

    •

    expand your discussion of net sales to address and quantify the impact that
volume sold, number of tooling projects completed and/or selling price had on
fluctuations in sales from period-to-period;

    •

    revise your discussion of gross margin to also quantify your raw material
costs, energy costs, and any other costs that significantly impact changes in
cost of sales from period-to-period; and

    •

    quantify the significant reasons you identify for changes in SG&A expenses.
See Sections 501.04 and 501.12 of the Codification of Financial Reporting
Policies for guidance.

Response: The Company acknowledges the staff’s comment and has reviewed the
referenced guidance in Section 501.4 and 501.12 of the Codification of Financial Reporting
Policies. In future annual and quarterly filings the Company will provide additional
discussion and disclosure as indicated above.

The Company notes that with respect to quantifying the impact from the number of
tooling projects completed, tooling project sales are sporadic in nature and fluctuate in
regard to scope and related revenue. Therefore, the Company does not believe that the
specific number of tooling projects actually completed for a given period are necessarily
meaningful to an understanding of sales fluctuations. The Company will however make
appropriate disclosure in the future to ensure that its discussion of net sales is
appropriately expanded, and includes those areas that the Company believes are meaningful to
an understanding of period-to-period sales fluctuations.

Liquidity and Capital Resources, page 22

6. Given the importance of available funding to your business, if you believe that it is
reasonably likely that you will not meet any significant debt covenant, please revise future
filings to also present, for your most significant covenants, your actual ratios and other actual
amounts versus the minimum/maximum ratios/amounts permitted as of each reporting date. Such
presentation will allow an investor to easily understand your current status in meeting your
financial covenants. Refer to Section 501.13.c of the Financial Reporting Codification for
guidance.

Squire, Sanders & Dempsey L.L.P.

Securities and Exchange Commission

October 27, 2010

Page 4

Response: The Company acknowledges the staff’s comment and has reviewed the
referenced guidance in Section 501.13.c of the Codification of Financial Reporting Policies.
At each annual and interim reporting period the Company evaluates compliance with all
significant debt covenants and completes an analysis to validate the Company’s ability to
effectively meet all significant covenants for the next twelve months, based on the
Company’s forecast. The Company also considers certain negative volatility to that forecast
when evaluating its ability to meet significant covenants. The Company has determined and
disclosed that it expected to maintain compliance with all significant covenants. In the
future if the Company were to determine that there was reasonable likelihood that it may not
meet a covenant, the Company will provide quantitative and qualitative disclosure as
required in Section 501.13.c of the Financial Reporting Codification.

Definitive Proxy Statement on Schedule 14A filed April 16, 2010

Directors and Executive Officers of Core Molding Technologies, Inc., page 6

7. Please disclose in future filings the business experience during the past five years of
Messrs. Thomas R. Cellitti and Malcolm M. Prine. Refer to Item 401(e)(1) of Regulation S-K.

Response: The Company acknowledges the staff’s comment and will disclose in
future filings the business experience during the past five years of Messrs. Cellitti and
Prine.

Executive Compensation, page 12

8. We note that you have not included any disclosure in response to Item 402(s) of Regulation
S-K. Please advise us of the basis for your conclusion that disclosure is unnecessary and describe
the process that you undertook to reach that conclusion.

Response: The Company’s Chief Executive Officer in conjunction with the
Director of Human Resources examines, on an annual basis, the compensation for all
employees, including named executive officers, and develops initial recommendations for the
salary component of compensation for consideration by the Board of Directors of the Company
(the “Board”). As part of this process, the Company’s Chief Executive Officer concluded
that the Company’s policies and practices with respect to compensation do not create risks
that are reasonably likely to have a material adverse effect on the Company. These
recommendations with respect to compensation were presented to the full Board for
consideration and approval.

While the Company does not have a separately constituted Compensation Committee, the
independent members of the Company’s Board review, recommend, approve and set compensation
policies as it relates to the Company’s named executive officers, and also consider the
overall policies and practices utilized by senior management with respect to establishing
compensation for all other employees. As part of that review process the Board agreed with
the assessments of the Company’s Chief
Executive Officer, and as part of its determination to approve the current compensation
packages, determined that the Company’s policies and practices with respect to compensation
are not reasonably likely to have a material adverse effect on the Company.

Squire, Sanders & Dempsey L.L.P.

Securities and Exchange Commission

October 27, 2010

Page 5

In reaching the foregoing conclusions, both the Board and the Chief Executive Officer
assessed the risks associated with the Company’s compensation policies and practices. The
basis for these conclusions included:

    •

    Consideration of the Company’s existing compensation programs, and the
allocation between each primary component of compensation (base salary, annual
profit sharing and long-term equity based compensation); and

    •

    a consideration of the risks associated with the Company’s business, and
whether the Company’s compensation policies and practices increased those
risks.

Based on the foregoing, management and the independent members of the Board approved
the Company’s compensation programs, and in connection with such approval concluded that the
risks associated with the Company’s compensation policies and practices are not reasonably
likely to have a material adverse effect on the Company.

In connection with the preparation of the proxy statement for the 2011 annual meeting
of stockholders, the Company’s management and the independent members of the Board will
conduct similar assessments of whether the Company’s compensation practices, including
compensation practices for other employees, create risk-taking incentives that could
reasonably be expected to have a material adverse effect on the Company, and will report
those findings in light of the disclosure requirements under Item 402(s) of Regulation S-K.

Elements of Direct Compensation, page 12

9. We note the disclosure under “Peer Group Analysis” on page 13 that you target your
compensation to the median of your peer group. With a view towards future disclosure, please tell
us each element of compensation and total compensation where actual compensation fell compared to
the peer group.

Response: As disclosed on page 13 of the Company’s proxy statement, the Company
collects competitive data regarding base salaries, annual bonuses and long-term incentive
awards from the peer group companies identified. The Company’s Board primarily looks to the
base salary component of the peer group as a guide in establishing the base pay component
for the Company’s named executive officers, although no salary increases have been
authorized by the Board due to current economic conditions since it last collected peer
group data in 2008.

As a general matter the Board does not look to the peer group for purposes of
benchmarking specific equity awards and non-equity bonus compensation. Equity
awards in the form of restricted stock awards are, as described in response to comment
11 below, consistently calculated as 30% of each named executive officer’s annual base
salary, less any annual compensation expense associated with previous stock option grants,
divided by the Company’s stock price on the date of grant. Non-equity awards in the form of
profit sharing are, as described in response to comment 10 below, based upon a formula for
participation and a profit sharing threshold equal to 8.0% of the Company’s adjusted average
assets.

Squire, Sanders & Dempsey L.L.P.

Securities and Exchange Commission

October 27, 2010

Page 6

The level of base compensation as compared to the Company’s peer group is only one of
several factors that the independent members of the Board consider in setting base
compensation, and is considered as a reference point to balance the costs of the Company’s
compensation program with expected performance. As disclosed in the Company’s proxy
statement, the Company considers a variety of factors in establishing each element of
compensation, including the named executive officer’s position, skills and experience,
individual performance, cyclicality in the Company’s business and the salaries of executives
with comparable positions and responsibilities at peer companies.

The Company generally targets base salary for each named executive officer based upon
the median, but also looks to where base salary falls with respect to the average of all
base salary amounts within the peer group. For the years 2007 through 2009, the base salary
component for each of the Company’s named executive officers has been lower than the average
for each category of named executive officer in the peer group.

Each element of compensation and total compensation for the Company’s named executive
officers for 2009 is set forth below, along with the 2008 peer group average for comparison
purposes:

    Non-Equity

    Total

    Base Salary

    Compensation

    Equity Awards

    Compensation

    Peer

    Peer

    Peer

    Peer

    Group

    Group

    Group

    Group

    Actual

    Average

    Actual*

    Average

    Actual

    Average

    Actual

    Average

    Kevin L. Barnett

President and Chief
Executive Officer

    $
    251,619

    $
    402,000

    $
    0

    $
    109,000

    $
    81,002

    $
    83,000

    $
    352,220

    $
    669,000

    Stephen J. Klestinec

VP & COO

    $
    205,023

    $
    289,000

    $
    0

    $
    44,000

    $
    65,999

    $
    48,000

    $
    288,024

    $
    393,000

    Herman F. Dick, Jr.

VP, Secretary,
Trea