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SEC Comment Letter for TTM TECHNOLOGIES INC (TTMI) (CIK 0001116942) (TTMI) — Apr 3, 2008

TTM TECHNOLOGIES INC (TTMI) (CIK 0001116942)
Date: April 3, 2008 · CIK: 0001116942 · Accession: 0000000000-08-017543

AI Filing Summary & Sentiment

File numbers found in text: 333-148687

Referenced dates: February 15, 2008

Date
March 21, 2008
Author
Not clearly detected
Form
UPLOAD
Company
TTM TECHNOLOGIES INC (TTMI) (CIK 0001116942)

Letter

Mail Stop 4561 A p r i l 3 , 2 0 0 8 Mr. Kenton K. Adler Chief Executive Office TTM Technologies, Inc. 2630 South Harbor Boulevard Santa Ana, CA 92704 Re: TTM Technologies, Inc. Amendment No. 2 to Form S-3 Filed March 21, 2008 File No. 333-148687

Dear Mr. Adler:

We have reviewed your response to our letter dated February 15, 2008 in connection with the above referenced fili ng and have the following comments. If indicated, we think you should re vise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Pleas e be as detailed as necessary in your explanation. After reviewing this information, we may raise additional comments. Incorporation of Certain Info rmation by Reference, page ii

1. The incorporated Form 10-K for the year ended December 31, 2007 does not currently include the Part III informa tion, which you incorporate by reference from a definitive proxy statement that has not yet been filed. Prior to the desired effective date of the registration statemen t, the information required by Part III of Form 10-K must be filed in an amende d Form 10-K that is incorporated by reference into the Form S-3, or in a filed, definitive proxy statement . See Interpretation H.6 of the July 1997 Ma nual of Publicly Available Telephone Interpretations of the Division of Corporation Finance.

***** As appropriate, please amend your filing in response to these comments. Each responsive amendment should also include a marked copy of the amended filing that conforms with the provisions of Rule 310 of Regulation S-T. Marked copies such as those in HTML format that show changes w ithin paragraphs help us to expedite our review. Please furnish a cover letter with your amendments that keys your responses to our comments and provides any requested in formation. Detailed cover letters greatly

Mr. Kenton K. Adler April 3, 2008 TTM Technologies, Inc. Page 2 facilitate our review. Please understand th at we may have additional comments after reviewing your amendments and responses to our comments. In view of the fact that we have furthe r comments, please confirm in writing that you have withdrawn your prior request for acce leration of the effective date of the registration statement. To facilitate the proce ssing of your filing we suggest that you submit another request for acceleration only after receiving oral assurances that we have no further comments. If you have any questions, please call LaTonya Reynolds at (202) 551-3535. Should you require further assistance, you may contact me at (202) 551-3462. S i n c e r e l y , M a r k P . S h u m a n B r a n c h C h i e f - L e g a l

cc: Via Facsimile: (602) 445-8615

Michael L. Kaplan, Esq. Greenberg Traurig, LLP

Show Raw Text
Mail Stop 4561         A p r i l  3 ,  2 0 0 8   Mr. Kenton K. Adler Chief Executive Office TTM Technologies, Inc. 2630 South Harbor Boulevard Santa Ana, CA 92704
Re: TTM Technologies, Inc.
  Amendment No. 2 to Form S-3
Filed March 21, 2008
  File No. 333-148687

Dear Mr. Adler:

We have reviewed your response to our letter dated February 15, 2008 in
connection with the above referenced fili ng and have the following comments.  If
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Pleas e be as detailed as necessary  in your explanation.  After
reviewing this information, we may raise additional comments.
 Incorporation of Certain Info rmation by Reference, page ii

1. The incorporated Form 10-K for the year ended December 31, 2007 does not currently include the Part III informa tion, which you incorporate by reference
from a definitive proxy statement that has not  yet been filed.  Prior to the desired
effective date of the registration statemen t, the information required by Part III of
Form 10-K must be filed in an amende d Form 10-K that is incorporated by
reference into the Form S-3, or in a filed, definitive proxy statement .  See Interpretation H.6 of the July 1997 Ma nual of Publicly Available Telephone
Interpretations of the Division of Corporation Finance.

*****
  As appropriate, please amend your filing in response to these comments.  Each responsive amendment should also include a marked copy of the amended filing that conforms with the provisions of Rule 310 of Regulation S-T.  Marked copies such as
those in HTML format that show changes w ithin paragraphs help us to expedite our
review.  Please furnish a cover letter with your amendments that keys your responses to
our comments and provides any requested in formation.  Detailed cover letters greatly

Mr. Kenton K. Adler
April 3, 2008 TTM Technologies, Inc. Page 2  facilitate our review.  Please understand th at we may have additional comments after
reviewing your amendments and responses to our comments.
In view of the fact that we have furthe r comments, please confirm in writing that
you have withdrawn your prior request for acce leration of the effective date of the
registration statement.  To facilitate the proce ssing of your filing we suggest that you
submit another request for acceleration only after receiving oral assurances that we have
no further comments.
 If you have any questions, please call LaTonya Reynolds at (202) 551-3535.
Should you require further assistance, you may contact me at (202) 551-3462.             S i n c e r e l y ,             M a r k  P .  S h u m a n          B r a n c h  C h i e f  -  L e g a l

cc:  Via Facsimile: (602) 445-8615

Michael L. Kaplan, Esq.
Greenberg Traurig, LLP