SecProbe.io

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SMART MODULAR TECHNOLOGIES (WWH), INC.

4211 Starboard Drive

Fremont, CA 94538

September 27, 2005

Securities and Exchange Commission

Division of Corporation Finance

100 Fifth Street, N.E.

Washington, D.C. 20549

Attention:Mr. Timothy Buchmiller, Esq.

    Re:

    SMART Modular Technologies (WWH), Inc.

    Amendment No. 1 to

    Registration Statement on Form S-4

    Request for Acceleration

Ladies and Gentlemen:

     Further to our request that the Amendment No. 1 to the Registration Statement on Form S-4
(File No. 333-127442) of SMART Modular Technologies (WWH), Inc. (the “Company”), relating to the
Company’s offer to exchange its Senior Secured Floating Rate Notes due 2012 for its Senior Secured
Floating Rate Exchange Notes due 2012, be declared effective by the Securities and Exchange
Commission (the “Commission”) on September 27, 2005 at 1:00 p.m., or as soon thereafter as is
practicable, we hereby acknowledge that:

    •

    should the Commission or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;

    •

    the action of the 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

    •

    the Company may not assert this action as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

    Very truly yours,

SMART MODULAR TECHNOLOGIES (WWH), INC.

    By:
    /s/ Ann Nguyen

    Name:
    Ann Nguyen

    Title:
    General Counsel and Assistant  Secretary