Via Edgar Filing

Kevin Stertzel and Claire Erlanger

Division of Corporation Finance

Office of Manufacturing

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re: BOEING CO

Form 10-K

Filed January 31, 2024

File No. 001-00442

Dear Mr. Stertzel and Ms. Erlanger:

We acknowledge receipt of your letter dated April 12, 2024. Further to our telephone conversation on April 15, 2024, we respectfully request an extension of an additional 10 business days to submit our response. We are currently completing first quarter close and preparing for the earnings release and 10-Q filing. An extension will allow more time to research and provide more thorough and thoughtful responses to your questions. We confirm that we will provide a written response to the comment letter by May 10, 2024.

If you would like to speak with us about this matter, please do not hesitate to call me at (630) 248-6275.

Sincerely,

Michael J. Cleary

Senior Vice President and Controller