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                              October 25, 2021

       Jason Aiken
       Chief Financial Officer
       General Dynamics Corporation
       11011 Sunset Hills Road
       Reston, Virginia 20190

                                                        Re: General Dynamics
Corporation
                                                            Form 10-K for
Fiscal Year Ended December 31, 2020
                                                            Filed February 9,
2021
                                                            File No. 001-03671

       Dear Mr. Aiken:

              We have reviewed your October 5, 2021 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       September 21, 2021 letter.

       Response Letter Dated October 5, 2021

       Form 10-K for Fiscal Year Ended December 31, 2020

   1.                                                   We note your response
to prior comment 1. As part of your revised disclosure, please
                                                        include language
regarding the difficulties involved in assessing the timing and effect of
                                                        changes in
environmental and climate change laws or regulations.
   2.                                                   We note your response
to prior comment 2 states that none of the past or planned climate-
                                                        related projects,
individually or in the aggregate, involved material capital expenditures or
                                                        would require material
future capital expenditures. Provide us with additional analysis
                                                        supporting this
statement, including quantitative information and a description of your
                                                        climate-related
projects.
   3.                                                   Your response to prior
comment 3, which states that you have not identified any material
 Jason Aiken
General Dynamics Corporation
October 25, 2021
Page 2
         indirect consequences of climate-related regulation or business
trends, appears to be
         conclusory without providing sufficient supporting detail. Please
provide us with
         additional information explaining how you assessed the indirect
consequences of climate-
         related regulation or business trends for your defense segments and
your Aerospace
         segment, including with regard to the individual items noted in our
prior comment.
4.       In response to prior comment 3, you explain that if your U.S.
Government customers were
         to include a specification relating to greenhouse gas emissions,
carbon-based energy
         sources or other similar measures for one or more products, these
standards would apply
         equally to all competing bidders. Tell us how you would be affected by
increased
         competition to develop products that result in lower emissions if
required by your U.S.
         Government customers.
5.       Your response to prior comment 4 states that you have not identified
any significant
         physical effects of climate change on your operations and results that
are material, but
         does not appear to include adequate support for this statement. Please
provide us with
         additional detail regarding the physical effects of climate change,
including the items
         specifically noted in our prior comment.
6.       From your response to prior comment 5, we note that you face
transition risks and
         opportunities related to climate change, but they are not considered
to be material. Tell us
         about the transition risks you have identified related to climate
change and explain how
         you concluded that they are not material to your business, financial
condition, and results
         of operations.
7.       Your response to prior comment 6 states that you have not identified
any material
         litigation risks related to climate change. Please provide us with
additional support for
         this statement and tell us how you considered providing disclosure
addressing the risks
         associated with the possibility of climate or environmental-related
litigation and its
         potential impact.
8.       We note from your response to prior comment 7 that you do not purchase
or sell carbon
         offsets that are material to your business, financial condition or
results of operations.
         Provide us with additional detail regarding purchases or sales of
carbon credits or offsets,
         including quantitative information.
      You may contact Wei Lu, Staff Accountant at (202) 551-3725 or Ethan
Horowitz,
Accounting Branch Chief at (202) 551-3311, if you have questions regarding the
comments.



FirstName LastNameJason Aiken                                  Sincerely,
Comapany NameGeneral Dynamics Corporation
                                                               Division of
Corporation Finance
October 25, 2021 Page 2                                        Office of
Manufacturing
FirstName LastName