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      Unassociated Document

    February
      6, 2007

    Ms.
      Pamela A. Long

    Assistant
      Director

    Securities
      and Exchange Commission

    Division
      of Corporation Finance

    100
      F.
      Street, N.E.

    Washington,
      D.C. 20549

    Re:
       Grupo
      Simec, S.A.B. de C.V.

    Registration
      Statement on Form F-1

    File
      No.
      333-138239

    Dear
      Ms.
      Long:

    In
      accordance with Rule 461 under the Securities Act of 1933, as amended, Grupo
      Simec, S.A.B. de C.V. (the “Company”) hereby respectfully requests the
      acceleration of the effective date of the above-referenced Registration
      Statement to 9:30 a.m. Eastern Standard Time on Thursday, February 8, 2007,
      or
      as soon thereafter as practicable.

    In
      connection with this request, the Company acknowledges that: (1) should the
      Securities and Exchange Commission or the staff, acting pursuant to delegated
      authority, declare the filing effective, it does not foreclose the Securities
      and Exchange Commission from taking any action with respect to the filing;
      (2)
      the action of the Securities and Exchange Commission or the staff, acting
      pursuant to delegated authority, in declaring the filing effective, does not
      relieve the Company from its full responsibility for the adequacy and accuracy
      of the disclosure in the filing; and (3) the Company may not assert this action
      as defense in any proceeding initiated by the Securities and Exchange Commission
      or any person under the federal securities laws of the United States.

    Please
      contact Walter Van Dorn at (212) 912-7446 or Marc Rossell at (212) 912-7430
      of
      Thacher Proffitt & Wood LLP
      once you
      have declared the above-referenced Registration Statement effective or if you
      have any questions.

    Sincerely,

    /s/
      Jose Flores Flores

    Jose
      Flores Flores,

    Chief
      Financial Officer

    cc:
       Craig
      Slivka,

    Securities
      and Exchange Commission

    Luis
      García Limón,

    Grupo
      Simec, S.A.B. de C.V.

    Michael
      L. Fitzgerald

    Taisa
      Markus,

    Milbank,
      Tweed, Hadley & McCloy LLP

    Marc
      M.
      Rossell

    Walter
      G.
      Van Dorn, Jr.

    Amelia
      G.
      Baker,

    Thacher
      Proffitt & Wood LLP