September 5, 2024

Ashish Chand
President and Chief Executive Officer
Belden Inc.
1 North Brentwood Boulevard
15th Floor
St. Louis, MO 63105

       Re: Belden Inc.
           Definitive Proxy Statement on Schedule 14A
           Filed April 9, 2024
           File No. 001-12561
Dear Ashish Chand:

      We have limited our review of your most recent definitive proxy statement
to those issues
we have addressed in our comment(s).

       Please respond to this letter by providing the requested information
and/or confirming that
you will revise your future proxy disclosures in accordance with the topics
discussed below. 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.

Definitive Proxy Statement on Schedule 14A
Pay Versus Performance, page 30

1.     Refer to your tabular columns showing compensation actually paid amounts
for
       PEOs Chand, Vestjens and Roel. Since Dr. Chand and Messrs. Vestjens and
Stroup were
       all    PEO   s, as defined in Item 402(a)(3) of Regulation S-K, please
revise future filings to
       use the term PEO in these column headings, rather than    NEO.    Note
that Item 402(v) of
       Regulation S-K contemplates separate disclosure for the PEO and the
non-PEO named
       executive officers.
2.     Refer to the second, third and fourth columns in your pay versus
performance table, which
       include Summary Compensation Table totals for the three PEOs. Although
these columns
       appear to include the same category of information, only the third and
fourth column
       headings include the    (b)    designation. The same presentation
appears in the fifth, sixth
       and seventh column headings with a    (c)    designation appearing only
in the fifth and sixth
 September 5, 2024
Page 2

       column headings. Please tell us the distinction, if any, between the
categories of data in
       these columns and revise future filings as applicable.
3.     We note that you have included    Adjusted Earnings Per Share,    a
non-GAAP measure, as
       your Company-Selected Measure pursuant to Item 402(v)(2)(vi) of
Regulation S-K.
       While Company-Selected Measure disclosure is not subject to Regulation G
or Item 10(e)
       of Regulation S-K, you must disclose how the measure is calculated from
your audited
       financial statements. Please tell us and revise future disclosure to
explain how this number
       is calculated from your audited financial statements. If the disclosure
appears in a
       different part of the definitive proxy statement, you may satisfy the
disclosure
       requirement by a cross-reference thereto. We note that you refer in
footnote (5) to your
       2023 Annual Report on Form 10-K, filed on February 8, 2024, for a
presentation of your
       Company-Selected Measure. We are unable, however, to locate any
Adjusted Earnings
       Per Share    disclosure in that filing. In addition, incorporation by
reference to a separate
       filing will not satisfy the Item 402(v)(2)(vi) of Regulation S-K
requirement to disclose
       how the Company-Selected Measure is calculated from your audited
financial statements.
4.     Refer to footnote (6) to your pay versus performance table where you
disclose a change in
       the    Compensation Actually Received    amounts for 2022. Please tell
us whether
          Compensation Actually Received    is calculated differently from
compensation actually
       paid and if so, explain how the difference relates to or is derived from
the referenced
          SEC Guidance released in November of 2023.
5.     We note the graph titled    Compensation Actually Paid v. Net Income
on page 33. Please
       ensure the data point representing net income for 2020 aligns with the
appropriate value
       for the 2020 net income as reported in your pay versus performance
table.
        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 absence of
action by the staff.

       Please contact Charlotte Young at 202-551-3280 or Amanda Ravitz at
202-551-3412 with
any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Disclosure Review
Program