SecProbe.io

CORRESP
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Simpson Thacher & Bartlett
llp

425 Lexington Avenue

New York, N.Y. 10017-3954

(212) 455-2000

Facsimile (212) 455-2502

    Direct Dial Number
    E-Mail Address

    (212) 455-7433
    dwilliams@stblaw.com

December
4, 2013

Mr. John Cash

Branch Chief

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

 Re: Grupo Simec, S.A.B. de C.V. Form 20-F for year ended December 31, 2012

Filed May 15, 2013, File No. 1-11176

Ladies
and Gentlemen:

On
behalf of Grupo Simec S.A.B. de C.V. (the “Company”), we are writing to respond to the comments set forth in
the Commission’s staff’s comment letter dated October 24, 2013 (the “comment letter”) relating to
the above-referenced annual report (the “Annual Report”) of the Company originally submitted on May 15, 2013,
pursuant to the Securities Act of 1934, as amended. For convenience of reference, we have reproduced below in italics the text
of the comments of the Staff. The responses and information described below are based upon information provided to us by the Company.

Form 20-F for the year
ended December 31, 2013

26. Contingencies, page F-45

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

 1. We have read your response to prior comment eight of our letter dated August 19, 2013. Please revise future disclosures
to: quantify the penalties recommended by the technical division of the DTSC; quantify any amount accrued and/or explain why amounts
have not been accrued; and update the status of your communications with DTSC, including when you expect this matter to be resolved.

As requested,
in its future disclosures the Company will: quantify the penalties recommended by the technical division of the DTSC; quantify
any amount accrued and/or explain why amounts have not been accrued; and update the status of its communications with DTSC, including
when it expect this matter to be resolved.

    Beijing

        Hong
        Kong

    Houston
    London
    Los Angeles
    Palo Alto
    São Paulo
    Seoul
    Tokyo
    Washington, D.C.

      2

Please call
me (212-455-7433) with any questions you may have regarding the above responses.

    Very truly yours,

    /s/ David L. Williams

    David L. Williams

cc:    Mario
Moreno Cortez

      3

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

Calzada Lázaro
Cárdenas 601

Colonia La
Nogalera, Guadalajara,

Jalisco, México
44440

Mr. John Cash

Branch Chief

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

 Re: Grupo Simec S.A.B. de C.V., Form 20-F for year ended December 31, 2012

Filed May 15, 2013, File No. 1-11176

Ladies and Gentlemen:

In
response to the Commission’s staff’s comment letter dated October 24, 2013 (the “comment letter”)
relating to the above-referenced annual report (the “Annual Report”) of Grupo Simec S.A.B. de C.V. (the “Company”),
originally submitted on May 15, 2013 pursuant to the Securities Act of 1933, as amended, the Company confirms its acknowledgment,
in connection with its responses to the comment letter that:

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

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

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

    Very truly yours,

    GRUPO SIMEC S.A.B. de C.V.

    By:
     /s/ Mario Moreno Cortez

    Name: Mario Moreno Cortez

    Title: Coordinator of Finance