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                              January 19, 2022

       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 November 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
       October 25, 2021 letter.

       Response Letter Dated November 5, 2021

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

   1.                                                   We note the description
of your risk-management program provided with your response to
                                                        prior comment 3. Please
tell us about the indirect consequences of climate-related
                                                        regulation or business
trends identified as part of your risk assessment, such as those noted
                                                        in comment 3 in our
letter dated September 21, 2021, and further explain how
                                                        management determined
that they are not material.
   2.                                                   Your response to prior
comment 5 states you have not incurred any material costs arising
                                                        from weather-related
damages to property or operations in recent years. Please provide us
                                                        with quantitative
information to support this statement.
   3.                                                   We note from your
response to comment 5 that business units potentially affected by
 Jason Aiken
General Dynamics Corporation
January 19, 2022
Page 2
         severe weather events address and mitigate the risk through your
corporate risk
         management process. As certain sites appear to be vulnerable to severe
weather events,
         explain further how you considered providing disclosure of material
risks of, or
         consequences from, such events.
      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
January 19, 2022 Page 2                                      Office of
Manufacturing
FirstName LastName