SecProbe.io

August 19, 2013

Via E -mail
Mr. Mario Moreno Cortez, Coordinator of Finance
Group Simec
Calzada Lázaro Cárdenas 601
Colonia La Nogalera, Guadalajara
Jalisco, México   44440

Re: Group Simec
 Form 20-F for the year ended December 31, 2012
Filed May 15, 2013
File No. 1 -11176

Dear Mr. Cortez :

We have reviewed your filing an d 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please  tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Item 5. Operating and Financial Review and Prospects, page 45

1. We note your disclosure that in 2010, 2011 and 2012 you did not purchase coke or pellets
since your Lorain, Ohio blast furnace facility was idle during th at period .  Please tell us,
and revise future filings to disclose, the net carrying value of idled assets.  Also, to the
extent material, please tell us, and clarify in future filings, how you assess idled assets for
impairment.

Comparison of years ended Dec ember 31, 211 and 2012, page 52

2. Please revise future filings to provide a more robust discussion of your results of
operations by segment.  In addition, please revise future filings to provide a more
comprehensive discussion of changes in administrative ex penses.

Mr. Mario Moreno Cortez
Group Simec
August 19, 2013
Page 2

 Item 18 . Financial Statements

Report of Independent Registered Public Accounting Firm, page F -2

3. Based on the provisions of SAS No. 1, section 543.09, it appears to us that your primary
auditor was also required to refer to the audit report of th e other auditor in the last
sentence of the second paragraph of their report.  Please advise or revise.

5. Basis for the preparation and presentation of the financial statements, page F -12

Summary of significant accounting policies, page F -13

4. We note yo ur disclosures on page 22 that indicate  you have entered into a factoring
arrangement.  Please tell us, and revise future filings to clarify, your accounting policy
for this arrangement and provide any other disclosures required by IFRS 7.

16. Employee Benefits, page F -33

5. We note your disclosure that Republic participates in the Steelworkers Pension Trust and
that you account for this as a defined contribution plan.  To the extent applicable, please
explain to us why sufficient information is not availa ble for you to account for this plan
as a defined benefit plan.  Also, please revise future filings to provide all the disclosures
required by paragraph 148(c) and (d) of IAS 19.

18. Stockholders’ Equity, page F -38

6. Please revise future filings to include  all the information required by paragraph 79(a) of
IAS 1.  Also, please tell us, and clarify in future filings, why the amount of capital
disclosed in note 18(a) is not equal to the amounts in your consolidated statements of
financial position and consoli dated statements of changes in stockholders’ equity.

25. Segment Information, page F -43

7. It is not clear to us why your disclosures related to information about products and
information about geographic areas are labeled “unaudited .”  Please advise or rev ise.

26. Contingencies, page F -45

Department of Toxic Substances Control, DTSC, page F -45

8. Your disclosure states “On October 19, 2010 the technical division of the DTSC
recommended to the enforcement division of DTSC that it impose significant
penalties …”  Please tell us, and revise future filings to quantify, the penalties they
recommended and whether you have recorded a provision for these penalties.

Mr. Mario Moreno Cortez
Group Simec
August 19, 2013
Page 3

9. We note your disclosure that estimates you prepared related to potential remediation
measures range fr om USD$ .8 million to USD$ 1.7million and that you have recorded a
provision of USD$ .4 million.  Please tell us, and clarify in future filings, why your
provision is less than the low end of your range.

We urge all persons who are responsible for the acc uracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applica ble Exchange Act rules require.   Since the company and its management are
in possession of all fact s relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of t he disclosures they have made.

In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the
filing;

 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

 the company may not as sert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.

You may contact  Mindy Hooker  at (202) 551 -3732  or Anne McConnell  at (202) 551 -
3709  if you have questions regarding comments on the financial statements and related matters.
Please contact me at (202) 551 -3768  with any other questions.

Sincerely,

 /s/ John Cash

John Cash
Branch Chief