Form: CORRESP

Correspondence

CORRESP: Correspondence

Published on

DORMAN
New Since 1918


April 16, 2008

Ms. Linda Cvrkel
Branch Chief
United States Securities and Exchange Commission
100 F Street, N.E., Mail Stop 3561
Washington, D.C. 20549

RE: Dorman Products, Inc. Form 10-K for the fiscal year ended
December 27, 2007 - File No.0-18914

Dear Ms. Cvrkel:

Enclosed are our responses to your letter dated
April 3, 2008 (the "Comment Letter"). In order to facilitate your review, we
have included the Staff's comment followed by our response below, as well as a
copy of the Comment Letter.

Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations Change in Vacation Policy

1. We note the disclosure on page 14 of MD&A indicating that effective
December 31, 2006 the Company changed its vacation policy so that
vacation is earned ratably throughout the year rather than at the end
of the preceding year. We also note that this change resulted in a
reduction in your vacation accrual and vacation expense of $1.8
million in 2007. Please explain to us in further detail why the change
in your vacation policy at the beginning of fiscal 2007 resulted in
a $1.8 million dollar decline in the amount of vacation expense that
was recognized during this period. We may have further comment upon
receipt of your response.

Response:
The Company's vacation policy prior to January 1, 2007 was as
follows: All rights to the subsequent year's vacation vested to
employees of the Company on the last day of the current fiscal
year. As a result, on December 31, 2006, under this policy
employees were fully vested in all vacation for the 2007 fiscal
year, and the Company had recorded a corresponding vacation
liability in accordance with FAS 43.

Effective January 1, 2007 the Company modified its vacation policy
so that the current year's vacation time is earned ratably
throughout the current year. Since employees had vested all 2007
vacation time at the start of the year under the old policy, no
additional vacation time was earned in 2007. The Company
established its vacation accrual in accordance with FAS 43 in each
reporting period in 2007. As a result of the change, the Company
reduced its vacation liability throughout 2007, as the vacation
was taken, from $1.8 million at the beginning of the year to zero
at the end of the year as it had no liability for employee
vacation time at the end of its fiscal 2007 under the new policy.
This reduction in the accrual resulted in a $1.8 million reduction
to vacation expense in 2007. In 2008, the Company will continue to
recognize a vacation liability under FAS 43 in consideration of
the new vacation policy.
Note 1. Summary of Significant Accounting Policies
Product Warranties

2. We note that the expense recognized in connection with product
warranties has increased over the periods presented in your financial
statements. In future filings, please revise the notes to your
financial statements to include the reconciliations of changes in your
liabilities for product warranties required by paragraph 14b of FIN No.
45.

Response:
The notes to the Company's financial statements in future filings
will be revised to include the reconciliations of changes in
liabilities for product warranties required by paragraph 14b of FIN
No. 45.

Supplementary Financial Information
Quarterly Results of Operations

3. In future filings, please revise the disclosure of your quarterly
results of operations to discuss or cross-reference to a discussion of
any material charges or unusual items that impacted your results of
operations for the quarterly periods presented. For example, we note
from the disclosure in footnote 1 that you recognized goodwill
impairment charges of $0.4 million and $2.9 million, respectively
during the fourth quarter of 2007 and the second quarter of 2006.
Refer to the guidance in item 302(a)(3) of Regulation S-K.

Response:
In all future filings, we will revise the disclosure of our quarterly
results of operations to discuss or cross-reference to a discussion of
any material charges or unusual items that impacted our results of
operations for the quarterly periods presented.

Company Certification

The Company hereby acknowledges that:

o The Company is responsible for the adequacy and accuracy of the
disclosure in its filings;

o 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

o 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.

Kindly acknowledge receipt of this letter by time and date stamping the
attached duplicate copy of this letter and returning it to me in the self
addressed stamped envelope provided.

If you or any other member of the Staff have any questions or would
like to discuss these matters at greater length, please do not hesitate to
contact me at (215)712-5132 or, in my absence, Thomas Knoblauch, at (215)
712-5222.


Sincerely,



Mathias J. Barton
Chief Financial Officer


cc: Ms. Effie Simpson, Division of Corporation Finance
Richard N. Berman, Chairman and Chief Executive Officer
Thomas Knoblauch, Esq., Vice President - General Counsel
Jane K. Storero, Esq. Blank Rome LLP