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                             June 20, 2024

       Suman B. Mookerji
       Chief Financial Officer
       Ducommun Inc.
       200 Sandpointe Avenue, Suite 700
       Santa Ana, California 92707

                                                        Re: Ducommun Inc.
                                                            Form 10-K for the
Year Ended December 31, 2023
                                                            Form 8-K
                                                            Filed on February
15, 2024
                                                            Response dated May
13, 2024
                                                            File No. 001-08174

       Dear Suman B. Mookerji:

              We have reviewed your May 13, 2024 response to our comment letter
and have the
       following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our April 29,
       2024 letter.

       Form 10-K for the Year Ended December 31, 2023

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Critical Accounting Policies and Estimates
       Revenue Recognition, page 32

   1.                                                   We note your response
to prior comment 2, including the additional disclosures you
                                                        included in your
interim financial statements pursuant to ASC 250. However, based on the
                                                        purpose of CAE
disclosures and given the gross favorable and gross unfavorable changes
                                                        in estimates you
recognized during the periods presented, please tell us what consideration
                                                        you gave to disclosing
gross changes in estimates under your CAE disclosures or, more
                                                        fully explain to us,
and revise future filings to disclose, why you believe disclosing
                                                        cumulative catch-up
adjustments on a net basis, rather than on an aggregate gross basis,
 Suman B. Mookerji
Ducommun Inc.
June 20, 2024
Page 2
         would be more meaningful to readers, as noted in your response.

Consolidated Financial Statements
Note 15. Commitment and Contingencies, page 78

2.       We note your response to prior comment 3. You indicate that insurance
recoveries for
         losses on equipment are reflected in cash flows from investing
activities up to the net book
         value of the assets and all other recoveries are reflected in cash
flows from operating
         activities, as either part of net income or part of change in
operating assets. Please be
         advised, it appears to us that proceeds received from insurance
recoveries related to
         equipment are analogous to proceeds received from the sale or disposal
of equipment and,
         therefore, should be afforded similar treatment, as investing cash
flows. To the extent
         material, please reflect insurance recoveries for losses on equipment
in cash flows from
         investing activities in future filings or explain to us how you
determined limiting amounts
         reflected in cash flows from investing activities to the net book
value of the assets is
         appropriate and complies with ASC 230.
       Please contact Ernest Greene at 202-551-3733 or Anne McConnell at
202-551-3709 if
you have questions regarding comments on the financial statements and related
matters.



FirstName LastNameSuman B. Mookerji                            Sincerely,
Comapany NameDucommun Inc.
                                                               Division of
Corporation Finance
June 20, 2024 Page 2                                           Office of
Manufacturing
FirstName LastName