September 14, 2018

Mr. Robert Starr
Chief Financial Officer
Kaman Corporation
1332 Blue Hills Avenue
Bloomfield, Connecticut 06002

       Re: Kaman Corporation
           Form 10-K for the Year Ended December 31, 2017
           Filed February 27, 2018
           Form 10-Q for the Period Ended June 29, 2018
           Filed August 8, 2018
           File No. 1-35419

Dear Mr. Starr:

       We have limited our review of your filings 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 Year Ended December 31, 2017

General

1.    You state on page 43 of the 10-K that you provide composite components
and bearings
      products for Airbus platforms including the Airbus A320. A document
titled "Orders,
      Deliveries, Operators - Worldwide" on the Airbus website identifies Sudan
Airways and
      Syrian Air as having ordered, having taken delivery of, and operating
Airbus A320
      aircraft.

      Sudan and Syria are designated by the Department of State as state
sponsors of terrorism,
      and are subject to U.S. economic sanctions and/or export controls. Please
describe to us
 Mr. Robert Starr
FirstName LastNameMr. Robert Starr
Kaman Corporation
Comapany 14, 2018
September NameKaman Corporation
September 14, 2018 Page 2
Page 2
FirstName LastName
         the nature and extent of any past, current, and anticipated contacts
with Sudan and Syria,
         including contacts with their governments, whether through
subsidiaries, distributors,
         partners, resellers, customers, joint ventures or other direct or
indirect arrangements.
         Please also discuss the materiality of those contacts, in quantitative
terms and in terms of
         qualitative factors that a reasonable investor would deem important in
making an
         investment decision. Tell us the approximate dollar amounts of
revenues, assets and
         liabilities associated with those countries for the last three fiscal
years and the subsequent
         interim period. Address for us the potential impact of the investor
sentiment evidenced by
         divestment and similar initiatives that have been directed toward
companies that have
         operations associated with U.S.-designated state sponsors of
terrorism.
Form 10-Q for the period ended June 29, 2018

Financial Statements
3. Significant Accounting Policies Update
Revenue Recognition, page 9

2.       We note that you recognize revenue at a point in time for your K-MAX
program with
         revenue now being recognized upon delivery to the customer. Please
tell us, and disclose,
         if material, the significant judgments you made in determining that
this is the appropriate
         point to recognize revenue. Refer to ASC 606-10-25-30 and
606-10-50-19. Also, in order
         for us to better understand the change in your accounting policy for
this program, please
         provide us your analysis regarding why the timing of revenue
recognition for the K-MAX
         program changed from cost-to-cost revenue recognition under
percentage-of-completion
         accounting to the point-in-time method. Refer to ASC 606-10-25-27
through 29. Please
         specifically address your consideration of any customer deposits and
customer
         specifications for this program, as applicable.

13. Commitments and Contingencies
Offset Agreement, page 25

3.       In regard to your disclosures related to the offset agreement, please
more fully address the
         following:
           explain how the notional value was determined;
           clarify how and when you expect to satisfy the terms of this
agreement and when and
             by who your satisfaction of this agreement will be determined; and
           clarify when and how you expect to account for this agreement in
your financial
             statements.



       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
 Mr. Robert Starr
Kaman Corporation
September 14, 2018
Page 3

absence of action by the staff.

      You may contact Ernest Greene at 202-551-3733 or Anne McConnell at
202-551-
3709 with any questions.



                                                      Sincerely,
FirstName LastNameMr. Robert Starr
                                                      Division of Corporation
Finance
Comapany NameKaman Corporation
                                                      Office of Manufacturing
and
September 14, 2018 Page 3                             Construction
FirstName LastName