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                              June 10, 2024

       Thomas Dineen
       Chief Financial Officer
       Sturm, Ruger & Company, Inc.
       1 Lacey Place
       Southport, CT 06890

                                                        Re: Sturm, Ruger &
Company, Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2023
                                                            Filed February 21,
2024
                                                            File No. 001-10435

       Dear Thomas Dineen:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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.

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

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations - 2023
       Net Sales, Cost of Products Sold, and Gross Profit, page 25

   1.                                                   You disclose here, and
in your Form 10-Q for the fiscal quarter ended March 30, 2024,
                                                        that you have
experienced inflationary cost increases in materials, commodities, services,
                                                        wages, energy, fuel,
and transportation, which have contributed to reductions in your
                                                        gross profit between
periods. Please revise your MD&A in future annual and quarterly
                                                        filings to quantify the
impact of the inflationary pressures you experience and the resulting
                                                        impact to your cost of
products sold and gross profit. In addition, expand your disclosures
                                                        in future filings to
identify actions planned or taken, if any, to mitigate inflationary
                                                        pressures.
 Thomas Dineen
FirstName  LastNameThomas
Sturm, Ruger  & Company, Inc.Dineen
Comapany
June       NameSturm, Ruger & Company, Inc.
     10, 2024
June 10,
Page 2 2024 Page 2
FirstName LastName
Non-GAAP Financial Measure, page 28

2.       We note that you present EBITDA margin, but do not present the most
directly
         comparable GAAP measure, net income margin, with equal or greater
prominence. In
         future filings, for each non-GAAP financial measure you present,
please also present the
         most directly comparable GAAP measure with equal or greater prominence
in accordance
         with Item 10(e)(1)(i)(A) of Regulation S-K. This comment also applies
to your Form 10-
         Q for the quarterly period ended March 30, 2024, as well as to Exhibit
99.1 of your Form
         8-K filed on May 7, 2024.
Schedule II - Valuation and Qualifying Accounts, page 88

3.       Please remove the information relating to the Excess and obsolete
inventory reserve from
         this schedule in future filings. Note that amounts recorded in
separate accounts to
         recognize obsolete and slow-moving inventory are not considered
reserves for the purpose
         of this schedule because those amounts in substance represent normal
adjustments /
         impairment of inventory rather than true "reserves   . Refer to Rule
12-09 of Regulation S-
         X, SAB Topic 5.BB and ASC 330-10-35-14.
       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
absence of action by the staff.

       Please contact Dale Welcome at 202-551-3865 or Ernest Greene at
202-551-3733 with
any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Manufacturing