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CORRESP
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CORRESP

 300 Renaissance Center

Detroit, MI 48265-3000

 October 3, 2025

 VIA
EDGAR

 Division of Corporation Finance

 Office of
Manufacturing

 U.S. Securities and Exchange Commission

 100 F
Street, N.E.

 Washington, D.C. 20549

RE:
 General Motors Company

Form 10-K for the Year Ended December 31, 2024

Response Dated September 8, 2025

File No. 001-34960

To whom it may concern:

 This letter from General Motors Company
(“we”, “our”, “us”, “GM” or the “Company”) is in response to a comment from the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange
Commission (the “Commission”) received by letter dated September 30, 2025, relating to the Company’s Form 10-K for the Year Ended December 31, 2024 (“2024 10-K”) (File No. 001-34960) filed with the Commission on January 28, 2025 and our response dated September 8, 2025, to comments from the Staff received by
letter dated August 26, 2025.

 In this letter, we have recited the comments from the Staff in italicized, bold type and have followed each comment
with the Company’s response thereto.

 Response Letter Dated September 8, 2025

Company Responses to Staff Comments 1 Through 3, page 2

1.
 We note your responses to prior comments one through three. ASC 280-10-50-22, 25, and 26A through 26C require disclosure of certain amounts for each reportable segment, and ASC 280-10-50-30 requires reconciliations from totals of certain reportable segments’ amounts to consolidated amounts. Your tabular disclosure of segment information
includes certain amounts for Corporate, Total Automotive, and the consolidated entity that are not required by ASC 280 and should be removed from your Segment Reporting footnote. For example, because Total Automotive is not a reportable segment,
disclosure of “Earnings (loss) before interest and taxes – adjusted” for Total Automotive is not required by ASC
280-10-50-22. Similarly, the amount of other segment items disclosed for Total Automotive is not required by ASC 280-10-50-26B. Please revise your footnote to:

•

 Reconcile the total of the reportable segments’ measures of segment profit or loss to consolidated
income before taxes as required by ASC 280-10-50-30(b). Similarly, revise to reconcile other totals of reportable segments’
amounts, such as revenues, assets, and depreciation and amortization, to the corresponding consolidated amounts as required by ASC
280-10-50-30. Include amounts in the Eliminations or Eliminations/Reclassifications columns as part of these reconciliations. See
ASC 280-10-50-31. See also ASC
280-10-55-48;

•

 Include amounts attributable to “Corporate” separately from other reconciling items when
reconciling from total reportable segment amounts to consolidated amounts, rather than as currently presented in a separate column. See ASC
280-10-50-15;

•

 Remove the Total Automotive column; and

•

 Ensure your resulting disclosure does not present consolidated amounts of the measure of segment profit or
loss and other segment items as currently reflected in the Total column.

 In response to the Staff’s comment, in future
filings we will align our Segments footnote to the presentation as described above for all periods presented. An illustrative example of this presentation is included in the Exhibit attached hereto.

Should you have any questions or comments regarding the responses in this letter, please feel free to contact me at (313)
407-3260.

 Very Truly Yours,

 /s/ Christopher T. Hatto

 Christopher T. Hatto

 Vice President, Global Business Solutions and

 Chief Accounting Officer

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 Exhibit:

Revised Segment Footnote Table - For illustration purposes, we present below a revised version of the table summarizing key financial information
by segment, as of and for the year ended December 31, 2024, as presented in Note 23 of the Notes to Consolidated Financial Statements in the 2024 10-K. In particular, in future filings we would
add a new column to present a reportable segment total for all amounts presented, reposition the prior Corporate, Eliminations and Eliminations/Reclassifications columns as reconciling items to reconcile Total Reportable Segments Earnings (loss)
before interest and taxes-adjusted to Income before income taxes, and remove the Total Automotive and Total Company amounts for Net sales and revenue, Segment expenses and other items and Earnings (loss)
before interest and taxes-adjusted.

 At and For the Year Ended December 31, 2024:

GMNA

GMI

Cruise

GM Financial

Total
Reportable
Segments

 Net sales and revenue

157,509

13,890

257

15,875

187,532

 Segment expenses and other items(a)

(142,981
)

(13,587
)

(1,958
)

(12,911
)

(171,437
)

 Earnings (loss) before interest and taxes-adjusted

14,528

303

(1,701
)

2,965

16,095

 Adjustments(b)

(738
)

(4,262
)

(1,107
)

(320
)

(6,427
)

 Corporate

(1,193
)

 Eliminations

(33
)

 Automotive interest income

967

 Automotive interest expense

(846
)

 Net (loss) attributable to noncontrolling interests

(45
)

 Income before income taxes

8,519

GMNA

GMI

Cruise

GM Financial

Total
Reportable
Segments

Corporate

Eliminations

Total GM

 Net sales and revenue

157,509

13,890

257

15,875

187,532

206

(296
)

187,442

 Equity in net assets of nonconsolidated affiliates

4,447

1,449

— 

1,206

7,102

— 

— 

7,102

 Goodwill and intangibles

1,966

676

570

1,339

4,551

— 

— 

4,551

 Total assets

165,905

21,769

2,948

139,156

329,778

38,817

(88,834
)

279,761

 Expenditures for property

10,266

415

7

24

10,712

30

88

10,830

 Depreciation and amortization

5,963

506

25

4,883

11,377

80

— 

11,456

 Impairment charges

— 

— 

933

— 

933

— 

— 

934

 Equity income(c)

955

(4,400
)

— 

(256
)

(3,701
)

— 

— 

(3,701
)

(a)
 Segment expenses and other items for GMNA and GMI primarily include material and logistics; manufacturing;
equity income; selling, general and administrative people-related costs; advertising; information technology; engineering; professional services; and policy, campaign, and warranty. GM Financial items consist primarily of GM Financial interest
expense; leased vehicle depreciation; people-related costs; provision for loan losses and gains and losses on termination of leased vehicles. Cruise items primarily consist of people-related costs.

(b)
 Consists of charges related to the Buick dealerships and restructuring actions in GMNA; charges related to
manufacturing operations wind down in GMI; China restructuring actions in GMI, GMNA and GM Financial; and charges related to Cruise restructuring and Cruise realignment.

(c)
 Equity loss associated with our Automotive China JVs include impacts of the other-than-temporary impairment and
our portion of restructuring charges. Equity earnings related to Ultium Cells Holdings LLC are presented in Automotive and other cost of sales as this entity is integral to the operations of our business by providing battery cells for our EVs. Refer
to Note 8 for additional information.

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