VIA EDGAR
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May 13, 2008


Ms. Pamela A. Long
Assistant Director
Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 7010
100 F Street, N.E.
Washington, D.C. 20549


         Re:      Rogers Corporation
                  Annual Report on Form 10-K for the FYE December 30, 2007
                  Filed on February 27, 2008
                  File No. 1-4347


Dear Ms. Long:

     On behalf of Rogers  Corporation (the  "Company"),  set forth below are the
responses  of the  Company  to the letter  dated  April 29,  2008 (the  "Comment
Letter"),  containing  the comments of the Staff of the  Securities and Exchange
Commission to the Company's filing referenced above.

     The Company's  responses to each of the comments in the Comment  Letter are
set forth below and are numbered to  correspond to the comments set forth in the
Comment Letter,  which for convenience we have  incorporated  into this response
letter.




Ms. Pamela A. Long
Assistant Director
Securities and Exchange Commission
May 13, 2008
Page 2




Legal Proceedings, page 14
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Comment 1:

Please tell us, with a view toward future disclosure,  how many claimants in the
asbestos  litigation  do not assert any specific  amount of damages and disclose
the range of damages  asserted by all other  claimants.  For example,  "X claims
assert damages of $; X claims assert between $ and $ in compensatory and between
$ and $ in punitive damages; X claims seek compensatory damages of less than $,"
etc.

Response 1:

As we discuss in our existing asbestos-related  disclosure,  only a small number
of claims contain specified  damages.  This is because in many  jurisdictions in
which the claims are brought,  plaintiffs are prohibited from claiming  specific
amounts in this type of personal injury tort action, other than a minimum amount
which is required in order for the case to be litigated  in a jury trial,  which
the plaintiffs believe will be most favorable to them. For example,  many claims
are for "an amount in excess of $50,000" or "an amount in excess of $75,000", as
these are the  minimums  required  under court rules in order for the case to be
heard by a jury. This is in contrast to commercial  litigation,  in which actual
damage claims are generally  permitted.  The  prohibition  on specifying  damage
amounts  often  applies not only to the suit when filed but in the course of the
litigation itself - the plaintiff is never actually  permitted to specify to the
jury the amount of damages it is claiming.

In those  jurisdictions  in which  plaintiffs  are  permitted to claim  specific
damages, many plaintiffs nonetheless still choose not to do so. Furthermore,  in
those  situations in which  plaintiffs do claim  specific  damages,  the damages
claimed  generally  bear no relation to the  injuries  allegedly  suffered.  The
amounts cited are more of a litigation strategy than an actual recitation of the
alleged damages.  Particular plaintiff law firms will always claim, for example,
$5,000,000  in damages,  regardless of the  particular  case,  jurisdiction,  or
defendant.  Trial lawyers representing the defendants in these matters generally
consider these amounts meaningless.

In  addition,  in those few cases in which  damages are  permitted to be and are
actually  alleged,  Rogers  is  virtually  always  one of  several  if not  many
defendants  named. In these cases, the claimed damages are not allocated against
specific  defendants,  but rather  the broad  claim is made  against  all of the
defendants as a group. Therefore, even in those cases where specific damages are
alleged,  it is not possible to quantify the amount of damages that we are being
claimed against us and therefore our potential liability.


Ms. Pamela A. Long
Assistant Director
Securities and Exchange Commission
May 13, 2008
Page 3




Finally,  for those suits that have  claimed  specific  damages and that we have
settled,  the amounts that have been paid in settlement  bear no relation to the
amounts claimed.

For these  reasons,  we believe that data as to the number of claimants  that do
not assert any specific amount of damages and the ranges of damages by all other
claimants  is not  relevant and could cause  confusion  to  investors.  We will,
however,  continue to monitor  developments  and will disclose in future filings
such data as we believe may be  relevant  and not likely to cause  confusion  to
investors.




Def 14A Material
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Compensation Discussion and Analysis, page 13
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Comment 2:

Please  refer to the last  paragraph  of Section  II.B in Release No.  37-8732A,
which  states  that a  principal  executive  officer's  compensation  should  be
discussed  separately  where the policy or decisions for that executive  officer
are materially different.  In future filings, please revise your CD&A to discuss
in more detail  your  principal  executive  officer's  compensation,  as certain
amounts listed in your Summary Compensation Table appear to be based on policies
or decisions  that are  materially  different from the policies or decisions for
your other executive officers.

Response 2:

There are no material differences in compensation  policies for individual named
executive  officers.  The  amount  of  total  actual  compensation  paid  to our
principal executive officer, Robert Wachob, primarily results from the design of
our compensation plans, the Compensation and Organization  Committee's  analysis
of the  compensation of the principal  executive  officers of the peer companies
listed  on  page  13  and  survey  information   provided  by  this  committee's
compensation consultant, and the individual's performance and contribution.  The
following information summarizes information currently reported in the CD&A that
address the principal executive officer's compensation and in future filings, we
will include a narrative discussion explaining the material differences, if any,
in the  compensation  policies and  decisions  for  individual  named  executive
officers.  With respect to base salary and equity  incentive  compensation,  Mr.
Wachob's target  compensation award opportunity was based on the same factors as
the other named executive officers, but his compensation  opportunity was higher
as it reflected a greater degree of policy and decision  making  authority and a

Ms. Pamela A. Long
Assistant Director
Securities and Exchange Commission
May 13, 2008
Page 4




higher  level  of  responsibility   with  respect  to  strategic  direction  and
operational  results of the Company  inherent in his position as  President  and
Chief Executive Officer.  Mr. Wachob's target compensation award opportunity was
assessed  relative to other principal  executive  officers in the peer group and
survey information provided by this committee's compensation consultant. Also as
explained  on page 18 of the  Compensation  Discussion  &  Analysis,  non-equity
incentive  compensation  earned by Mr.  Wachob in 2006 and  reported in our 2007
proxy filing resulted in a substantial increase in Mr. Wachob's pension benefits
last year under the terms of the Rogers  Pension  Restoration  Plan as in effect
since 2004.


Market Positioning, page 14
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Comment 3:

We note your  disclosure that the company  positions  itself around or above the
50th percentile of the comparator company group for each compensation component.
In future  filings,  please  disclose where actual payments fell within targeted
parameters.  To the extent actual  compensation  was outside the targeted range,
please explain why.

Response 3:

In future  filings we will expand the  discussion of how the Committee uses peer
group and survey data in establishing compensation for named executive officers.
Please note,  however,  that we would not be able to provide  information  about
whether  actual  compensation  fell  outside of the targeted  range  because the
relevant peer group data - the actual  compensation  paid at the other companies
in the peer  group - would not be  available  until  after all the peer  group's
proxy statements had been filed.


Ms. Pamela A. Long
Assistant Director
Securities and Exchange Commission
May 13, 2008
Page 5




Equity Incentives, page 16
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Comment 4:

We note your  disclosure that the factors used in determining the amount of each
award is an assessment of the individual's job performance,  competitive  market
practices,  last year's award and the  individual's  potential impact on profits
for the entire corporation. In future filings, please describe in greater detail
how individual roles are measured in determining equity incentives.

Response 4:

We will, as appropriate, describe in greater detail how individual roles are
considered in structuring and impFlementing equity incentives in future
compensation discussion and analysis.




In response to the Staff's comments, the Company acknowledges that:

     1.      The Company is responsible for the adequacy and accuracy of the
             disclosure in the filing;

     2.      Staff comments or changes to disclosure in response to staff
             comments do not foreclose the Commission from taking any action
             with respect to the filing; and

     3.      The Company may not assert staff comments as a defense in any
             proceeding initiated by the Commission or any person under the
             federal securities laws of the United States.


     Please  telephone me at  860-774-9605,  or our attorney,  Andrew J. Merken,
Esq. of Burns & Levinson LLP, Boston, MA at 617-345-3740,  with any questions or
comments you may have.  In addition,  please  provide to us a copy of all future
correspondence via facsimile at 860-779-5585.


Ms. Pamela A. Long
Assistant Director
Securities and Exchange Commission
May 13, 2008
Page 6




                                        Very truly yours,


                                        /s/ Robert D. Wachob
                                        ----------------------------------------
                                        Robert D. Wachob
                                        President and Chief Executive Officer





cc:      Dennis M. Loughran, Vice President Finance and Chief Financial Officer
         Robert M. Soffer, Vice President and Secretary
         John A. Richie, Vice President, Human Resources
         Paul B. Middleton, Treasurer
         Debra J. Granger, Vice President, Corporate Compliance and Controls
         Ronald J. Pelletier, Manager, Financial Reporting
         Sean Lynch, Ernst & Young
         Andrew J. Merken, Esq., Burns & Levinson LLP