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September 3, 2025

VIA EDGAR TRANSMISSION

Ms. Mindy Hooker

Ms. Anne McConnell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: GRUPO SIMEC, S.A.B. de C.V.

Form 20-F for the Fiscal Year Ended December 31, 2024

Filed May 15, 2025

File No. 001-11176

Dear Ms. Hooker and Ms. McConnell:

By letter dated August 19,
2025, the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission
(the “Commission”) provided certain comments on the annual report on Form 20-F of Grupo Simec, S.A.B. de C.V. (the
“Company”) for the fiscal year ended December 31, 2024 (the “Form 20-F”). This letter sets forth
our responses to those comments. For your convenience, we have reproduced the Staff’s comments below in bold italics and have provided
the Company’s responses immediately following each comment.

Comment 1:

Form 20-F. Item 5. Operating and
Financial Review and Prospects, page 41

Please revise the financial and
other data presented in tabular formats in future filings to read consistently in the same chronological order throughout your filing.
Similarly, please also present numerical data in narrative disclosures consistently ordered throughout your filing. In this regard, we
note certain financial and other data in Item 5 is presented with the oldest period first and the consolidated financial statements are
presented with the most recent period first. Refer to SAB Topic 11:E.

Response:

The Company takes
note of the Staff’s comment and will revise its future Form 20-F filings to ensure consistent presentation of data in both tabular
and narrative formats.

Comment 2:

Form 20-F. Item 5. Operating and
Financial Review and Prospects, page 41

Please revise future filings to
ensure you provide updated and accurate disclosures that are consistent with information in your annual report filed in Mexico. We note,
for example, that energy cost disclosures on page 44 indicate an unusual decrease in the most recent period and the assumptions in the
valuation models of the San Luis reporting unit on page 60 seem to pertain to the prior year. Both examples appear to be inconsistent
with similar disclosures in your annual report filed in Mexico. Please be aware that these examples are not an exhaustive list, and you
should review all your disclosures to ensure they are updated and accurate and align with other public filings made by the company.

Response:

The Company takes
note of the Staff’s comment and will revise its disclosures in future Form 20-F filings to ensure consistency with its annual report
filed in Mexico.

Comment 3:

Form 20-F. Item 5. Operating and
Financial Review and Prospects, page 41

We noted numerous inconsistencies
and misstatements throughout your filing, for example:

 ● certain Sales Volume, Price and Cost Data 2024 related to the Republic facilities for 2024 on page
42 do not appear to be accurate;

 ● the tabular presentation of results by segment for 2024 on page 45 does not depict total gross profit
correctly;

 ● discussions of cost of sales on pages 47 and 50 imply costs at the Republic facilities increased
when they actually decreased;

 ● a discussion that other expense was recorded in 2024 and other income was recorded in 2023 does
not reconcile with the financial statements;

 ● discussions of a foreign exchange provision in 2024, and a foreign exchange loss in 2024, do not
reconcile with the foreign exchange gain in 2024 in the financial statements;

 ● discussions that state amounts increased when they actually decreased and/or that amounts decreased
when they actually increased; and

 ● discussions of consolidated information and segment information for certain periods included more
than once and/or included out of order.

Please be aware these examples
are not an exhaustive list, and you should review all disclosures in future filings to ensure they are accurate.

Response:

The Company takes
note of the Staff’s comment and will revise its future Form 20-F filings to correct the noted inconsistencies and misstatements
and ensure accuracy throughout.

Comment 4:

Form 20-F. Item 5. Operating and
Financial Review and Prospects, page 41

Please more fully explain
to us and revise future filings to address the following items.

 ● Explain the specific reasons for the declines in product volumes during the periods presented and
address the factors impacting this trend.

 ● Explain how the exchange gains and losses are determined for each period, including the assets,
liabilities and/or transactions they relate to, and explain the reasons for changes in such amounts during the periods presented.

 ● Explain the reasons for the decrease in the effective income tax rate for FY 24 and clarify whether
you anticipate the decrease is indicative of a trend in future effective income tax rates. Refer to Item 5 of Form 20-F.

Response:

The Company takes
note of the Staff’s comment and provides the following explanations, which will also be reflected in expanded disclosures in future
Form 20-F filings.

    2

Product volumes.
Our production volumes are closely tied to the performance of the Mexican economy, as our products are used in the automotive, construction,
manufacturing, and related industries. The decline in production volumes in recent years reflects a recession in the Mexican steel industry,
combined with demand fluctuations across these end-use sectors. According to data published by the Mexican National Institute of Statistics
and Geography (Instituto Nacional de Estadística y Geografía, or INEGI), the average monthly production value
(in millions of pesos) in the following years was:

 ● 2022: Ps. 28,584 million

 ● 2023: Ps. 20,290 million

 ● 2024: Ps. 11,725 million

Since 2021, production
has since declined significantly. This was due to (i) reduced domestic demand from construction, automotive, and manufacturing sectors,
which were impacted by economic uncertainty, inflation, and adjustments in public and private spending, and (ii) a slowdown in global
economic activity, which negatively affected exports.

Foreign exchange
gains and losses. Transactions denominated in currencies other than the Company’s functional currency are recognized using exchange
rates in effect on the dates of the transactions. At the end of each reporting period, monetary items denominated in foreign currency
are retranslated at the closing exchange rate, with the resulting differences recognized in profit or loss. The Company maintains a net
monetary asset position in foreign currency, so fluctuations in the Mexican peso/U.S. dollar exchange rate materially affect the recognition
of exchange gains and losses. As published by the Mexican Central Bank (Banco de México), the Mexican peso/U.S. dollar exchange
rates per U.S.$1.00 at December 31 of each year were:

 ● 2022: Ps. 19.36

 ● 2023: Ps. 16.89

 ● 2024: Ps. 20.51

These changes in
exchange rates explain the variability in the Company’s reported foreign exchange gains and losses across the periods presented.

Effective tax
rate. The decrease in the Company’s effective income tax rate for 2024 was primarily due to foreign currency conversion effects
related to U.S. dollar-denominated investments. In 2024, the Mexican peso appreciated by Ps. 3.62 per U.S. dollar, generating a financial
gain that, under Mexican tax law, does not have tax consequences. This nontaxable gain significantly reduced the effective tax rate for
the period. The Company will revise its disclosures in future Form 20-F filings to include additional discussion of these effects and
to clarify that the 2024 reduction is not necessarily indicative of a trend in future effective tax rates.

    3

Comment 5:

Form 20-F. Item 5. Operating
and Financial Review and Prospects, page 59

We have the following comments
regarding the cessation of operations at Republic Steel and the related disclosures beginning on page 59. Please tell us and revise future
filings to clarify the following items.

 ● Explain your current intentions regarding Republic Steel and its remaining assets.

 ● Explain how you are accounting for Republic Steel’s assets since you ceased operations. Refer to
IFRS 5 and IAS 16.

 ● In the third paragraph on page 59, you quantify assets related to the Lorain, Ohio facility for
the years 2022, 2021 and 2020. Quantify amounts related to the current periods presented.

 ● In the fourth paragraph on page 59, we note you “performed an analysis of the fair value of
the four facilities (Canton, Solon, Massillon and Lackawanna) and determined net book value exceeded fair value by approximately U.S.
$130.7 million (Ps. 2,701 million) and as such recognized an asset impairment of this amount during the year ended December 31, 2015”.
This disclosure appears to relate to the Lorain facility impairment analysis described in the preceding paragraph. Tell us and revise
future disclosures to clearly indicate the results of the impairment analyses performed on your U.S. facilities in 2023 and indicate whether
you performed impairment analyses on any or all of Republic Steel’s assets in 2024. If so, explain the results. If not, explain why not.

 ● You indicate the existing inventory balance related to Republic Steel’s facilities is Ps. 5,796,451
(Ps. 4,496,211 in short-term and Ps. 1,300,240 in long-term) and that you have physical coke inventory of Ps. 1,414,703 at December 31,
2024 at these facilities. Explain why the physical coke inventory balance is greater than the long-term inventory balance. Also, provide
us an analysis of Republic Steel’s inventory balance by type as of December 31, 2024, explain how you determined carrying value was less
than NRV as of December 31, 2024, and explain why this inventory remains unsold.

 ● We noted numerous references to valuations performed by “an expert in the field”. Explain
your consideration of identifying the expert and filing their valuation report as an exhibit given your apparent reliance on it.

Response:

The Company takes
note of the Staff’s comment and provides the following explanations, which will also be reflected in expanded disclosures in future
Form 20-F filings.

Current intentions
regarding Republic Steel. At present, management has determined that the Republic Steel facilities will remain inactive unless there
are changes in prevailing economic conditions that justify resuming operations.

Accounting treatment
of Republic Steel assets. As of December 31, 2024, because management does not intend to sell the facilities, IFRS 5 (Non-current
Assets Held for Sale and Discontinued Operations) does not apply. Instead, the assets continue to be accounted for in accordance with
IAS 16 (Property, Plant and Equipment), measured at cost less accumulated depreciation and impairment, as appropriate. In addition, the
Company engaged an authorized appraiser to determine the fair value of the assets for purposes of assessing potential impairment under
IAS 36. No impairment was identified in 2024.

    4

Quantification
of Lorain facility amounts. The disclosures in the third paragraph of page 59 relate to the quantification of assets associated with
the “Grupo San” cash-generating unit, which was acquired in 2008 and gave rise to goodwill at the acquisition date. The Company
confirms that the value of the Lorain facility’s fixed assets has remained the same through the current periods presented. The Company
will revise its disclosures in future filings to provide quantification for these periods, if applicable.

Impairment analyses.
The reference to an impairment of approximately U.S.$130.7 million (Ps. 2,701 million) corresponds to an impairment recognized in 2015,
related to an electric arc furnace that ceased to be used that year and which used coke as a raw material. This disclosure is unrelated
to the Lorain facility impairment analysis referenced in the preceding paragraph. For 2023 and 2024, the Company engaged an authorized
appraiser to assess the fair value of Republic Steel’s assets in accordance with IAS 36. No impairment was identified.

Inventory balances.
The correct balances as of December 31, 2024 were Ps. 5,796,451 in total inventory, comprised of Ps. 4,381,748 in short-term inventory
and Ps. 1,414,703 in long-term inventory, as disclosed in Notes 4(e) and 9 to the consolidated financial statements. Physical coke inventory
at year-end was Ps. 1,414,703. The Company compared book values to net realizable values (NRV) and recorded write-downs where necessary.
As of December 31, 2024, a portion of Republic Steel’s inventory consisted of steel products that, if sold at current market prices,
would generate a loss; therefore, this inventory remains unsold.

Use of experts.
In selecting valuation experts, the Company undertook due diligence regarding their credentials, background, and professional reputation,
including verifying experience in the relevant industry. The Company relied on reports prepared by these experts for impairment testing
purposes. We will consider in future filings whether identification of the expert and/or filing of their valuation report as an exhibit
is required under applicable SEC rules, given our reliance on their analysis.

Comment 6:

Form 20-F. Item 15. Controls
and Procedures, page 92

We note your disclosure that your
CEO and CFO, “...after evaluating the effectiveness of our disclosure controls and procedures (as defined in Exchange Act Rule 13a-15(e))
as of the end of the period covered by this annual report, have concluded that, as of such date, our internal control over financial reporting
was effective.” Please be advised, as required by Item 15 of Form 20-F, management is required to provide separate conclusions on
the effectiveness of Disclosure Controls and Procedures and the effectiveness of Internal Control over Financial Reporting as of December
31, 2024. Please amend your Form 20-F to fully comply with the requirements of Item 15 of Form 20-F.

Response:

The Company takes
note of the Staff’s comment. We respectfully note that management did evaluate both disclosure controls and procedures (DCP) and
internal control over financial reporting (ICFR) as of December 31, 2024, and concluded that both were effective. The intent of our Item
15 disclosure was to cover both, and we believe the Company’s 2024 Form 20-F was not misleading in substance.

We understand, however,
the Staff’s position that Item 15 requires separate, explicit conclusions on the effectiveness of DCP and ICFR. In future Form 20-F
filings, we will revise our presentation to provide two distinct conclusions, one for DCP and one for ICFR, to align fully with Item 15.

Because management’s
evaluations and conclusions were properly made and disclosed, and the Staff’s comment concerns the structure rather than the substance
of our disclosure, we respectfully request that this comment be addressed in future filings rather than having to amend the 2024 Form
20-F. That said, should the Staff nonetheless prefer that we amend the 2024 Form 20-F to include the separate conclusion on DCP, the Company
is prepared to file a brief Form 20-F/A limited to this point.

    5

Comment 7:

Form 20-F. Item 18. Consolidated
Financial Statements, page F-35

Please more fully explain
to us and revise future filings to address the following items.

 ● The introduction to your tabular presentation indicates expenses are shown in parentheses; however,
the table presents income amounts in parentheses. Additionally, it appears the net income totals for FY 24 and FY 22 should be presented
without parentheses to be consistent with amounts presented in your consolidated statements of income. Ensure you provide accurate and
consistent financial information in future filings.

 ● Explain the nature of the amounts identified as Republic and GV “account debugging”.
In the event ac