Jason W. Aiken
Senior Vice President
Chief Financial Officer
October 19, 2017
Ms. Melissa Raminpour
Branch Chief, Office of Transportation and Leisure
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
| Re: | General Dynamics Corporation |
| Form 10-K for the Fiscal Year Ended December 31, 2016 |
| Filed February 6, 2017 |
| Form 10-Q for the Quarterly Period Ended July 2, 2017 |
| Filed July 26, 2017 |
| File No. 001-03671 |
Via Overnight Delivery and EDGAR
Dear Ms. Raminpour:
On behalf of General Dynamics Corporation, please note the company’s responses to comments addressed in your letter dated October 11, 2017.
Set forth below are our responses to your comments. To assist you in the review process, we have reproduced the comments in bold type.
Note B. Revenue, page 10
Performance Obligations, page 10
SEC Comment
| 1. | We have reviewed your response to prior comment 2. When separate contracts are entered into for various phases of the product lifecycle, please tell us how you consider the criteria for determining whether separate contracts should be combined as a single contract pursuant to ASC 606-10-25-9. |
General Dynamics’ Response
For programs in our defense business that have separate contracts for various phases of the product lifecycle, the time frame over which contracts are awarded generally spans several years, preceding each phase of the lifecycle (development, manufacturing, post-delivery maintenance and support). Because these contracts are not entered into at or near the same time as specified in ASC 606-10-25-9, they are not combined into a single contract. In the event that contracts for all or a portion of the contract lifecycle are
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jaiken@generaldynamics.com
October 19, 2017
Page 2
entered into at or near the same time with the same customer and meet one or more of the criteria in ASC 606-10-25-9, we would combine them as a single contract.
* * *
We would welcome the opportunity to discuss these comments with you further. In the meantime, please do not hesitate to contact me at (703) 876-3777 with any questions about these matters.
| Sincerely, |
| /s/ Jason W. Aiken |
| Jason W. Aiken |
| Senior Vice President and Chief Financial Officer |
| Cc: | David M. Lynn |
| Jenner & Block, LLP |
| 1099 New York Avenue, NW |
| Suite 900 |
| Washington, DC 20001 |