SecProbe.io

July 23, 2010
 Kenton K. Alder President and CEO TTM Technologies, Inc.
2630 South Harbor Boulevard
Santa Anna, CA 92704
Re: TTM Technologies, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 20009
Filed March 15, 2010 Form 8-K/A Filed April 26, 2010 File No. 000-31285

Dear Mr. Alder:
We have reviewed your filings and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
 Form 10-K for the Fiscal Year Ended December 31, 2009

 Item 1.  Business

 Customers and Markets, page 7

 1. We note in your risk factor disclosure that you appear to  be heavily dependent upon the
U.S. government for a substantial portion of your business.  Please explain why you have
not addressed your dependence on the U.S. gove rnment in your customer discussion.
Please also explain why you have not pr ovided the disclosure required by Item
101(c)(1)(ix) of Regulation S-K.

 Kenton K. Alder TTM Technologies, Inc. July 23, 2010 Page 2   Suppliers, page 9

 2. We note your disclosure in th is section that “most of our  raw materials are generally
available in the open market from numerous  other potential supplie rs.”  However, on
page 18, you state that “components for backplane assemblies in some cases have limited or sole sources of supply.”  We further note your response on this issu e to our letter dated
May 30, 2008, in which we raised comment s on your Form 10-K filed on March 17,
2008.  Please enhance your discussion of this issue in the Business section of future
filings.  In this regard, and as appropriate, we  would expect such disclosure to discuss the
use of raw materials from limited or sole s ources of supply in your backplane assembly
business segment.
 Backlog, page 9

 3. During your May 6, 2010 earnings call, you disclo sed a book to bill ratio for printed
circuit boards.  However, in your Business se ction, you do not disclose the dollar amount
of backlog orders believed to be firm, as of a recent date and as of a comparable date in
the preceding fiscal year, together with an in dication of the portion thereof not reasonably
expected to be filled within the current fiscal  year.  Given the apparent importance of this
measure to your business, please tell us how  you considered disclosing backlog amounts
in accordance with Item 101(c)(1 )(viii) of Regulation S-K.

Item 1A.  Risk Factors

 Our results of operations are often subject to  demand fluctuations and seasonality… page 20

 4. You indicate that you have “experienced sales fluc tuations due to seasonal patterns in the
capital budgeting and purchasing cycle, as we ll as inventory management practice of
[your] customers and the end markets [you] serve.”  It is unclear to us how you
considered disclosing the seasonality risks pertaining to your busin ess in your Business
description and Management’s Discussion and Analysis.  Refer to Item 101(c)(1)(v) and
Item 303(a)(3)(ii) of Regulation S-K.

Item 2.  Properties, page 32

 5. We note that you recently closed  two facilities. In future  filings, please address the
suitability, adequacy, productive capacity and extent of utilization of the owned and
leased facilities you identify.  Refer to In struction 1 to Item 102 of Regulation S-K.

 Kenton K. Alder TTM Technologies, Inc. July 23, 2010 Page 3  Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations
 Overview, page 37

 6. Your “Overview” appears to be more in the nature of a business description and summary
of certain financial results than a balanced, executive-level discussion that identifies the most important themes or other significant matters with which management is primarily
concerned in evaluating the company’s financ ial condition and operating results.  In
future filings, consider expanding your “Overview” to address, for instance, economic or industry-wide factors relevant  to the company and the material operational risks and
challenges facing you and how management is dealing with these issues.  Refer to
Section III.A of SEC Release No. 34-48960.  For example, consider discussing management’s expectations regarding the im pact of the PCB Combination and how it
intends to respond to the trends you identified on page 2.  This comment also applies to
your Quarterly Report on Form 10-Q for the quarterly period ended March 31, 2010.
 Item 8.  Financial Statements and Supplementary Financial Data

Consolidated Financial Statements
 Notes to Consolidated Financial Statements

 (6) Composition of Certain Consolidated  Financial Statement Captions, page 73

 7. We note in your disclosure here and in your schedule of valuation and qualifying
accounts on page 92 that you record inventory re serves for excess and obsolete inventory.
Tell us how you considered the guidance in Chapter 4 footnote 2 of ARB 43 and SAB
Topic 5BB, which indicates th at inventory write-downs due to obsolescence establish a
new cost basis and should not be presented as a reserve.  Please clarify how your
accounting method establishes a new cost ba sis for your inventory and why you believe
including this reserve as a valuation and qualifying account is appropriate.
 Item 10.  Directors, Executive Officers of the Registrant and Corporat e Governance Matters
(Incorporated by Reference from Definitive Pr oxy Statement on Schedule 14A, filed April 12,
2010)
 Committees of the Board of Directors, page 8

 8. Please advise what consideration you gave to  the requirements of It em 407(c)(2)(vi) of
Regulation S-K.  You indicate that your nom inating and corporate governance committee
considers diversity when recommending dir ector nominees for election and that the
committee “evaluates its effectiveness in achie ving diversity on the board of directors

 Kenton K. Alder TTM Technologies, Inc. July 23, 2010 Page 4
through its annual review of board member  composition, which identifies ethnicity,
gender, and industry experience.”  In future f ilings, we would expect to see more detailed
disclosure with respect to how your no minating and corporate governance committee
considers diversity in identif ying nominees for director, if  your nominating and corporate
governance committee has a policy with regard to the consideration of diversity in
identifying director nominees, and a descript ion of how this policy is implemented, as
well as how the nominating and corporate governance committee assesses the effectiveness of its policy.
 Item 11. Executive Compensation (Incorporated by Reference from Definitive Proxy Statement
on Schedule 14A, filed April 12, 2010), page 30
 9. Item 402 of Regulation S-K requires that you provide compensation information for your
principal executive officer (PEO ), principal financial officer  (PFO), and three of your
most highly compensated executive officers ot her than your PEO and PFO.  We note that
you provide compensation information for f our executive officers, including your PEO
and PFO, rather than five officers as contem plated by Item 402(a) of Regulation S-K.
Please advise.

Form 8-K/A filed April 26, 2010

 Exhibit 99.1

 Notes to the Financial Statements

 34 Reconciliation to US GAAP, page 73

 10. Please tell us how you considered the guidance of Item 17(C)(2)(iii) of Form 20-F.  In
this regard, it does not appear that you have presented a stat ement of cash flows prepared
in accordance with generally accepted accounting principles in the United States or with
International Accounting Standard No. 7 or alternatively, furnishing in a note to the
financial statements a quantif ied description of the materi al differences between cash
flows reported in accordance with Hong Kong Financial Reporting Standards and cash flows that would be reported in a statemen t of cash flows prepared in accordance with
accounting principles generally a ccepted in the United States.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 Kenton K. Alder TTM Technologies, Inc. July 23, 2010 Page 5
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact David Edgar, Staff Accountant, at (202) 551-3459 or Patrick Gilmore,
Accounting Branch Chief, at (202) 551-3406 if you have questions regarding comments on the
financial statements and related matters.  Plea se contact Courtney Haseley, Staff Attorney, at
(202) 551-3548 or me at (202) 551- 3735 with any other questions.

Sincerely,

Barbara C. Jacobs Assistant Director