SEC Comment Letter for TTM TECHNOLOGIES INC (TTMI) (CIK 0001116942) (TTMI) — Nov 18, 2010
TTM TECHNOLOGIES INC (TTMI) (CIK 0001116942)
Date: Nov. 18, 2010 · CIK: 0001116942 · Accession: 0000000000-10-069196
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File numbers found in text: 000-31285
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November 18, 2010
Mr. Steven Richards Executive Vice President and Chief Financial Officer TTM Technologies, Inc. 2630 South Harbor Boulevard Santa Ana, CA 92704
Re: TTM Technologies, Inc.
Form 8-K
Filed November 17, 2010 File No. 000-31285
Dear Mr. Richards:
We have reviewed your filing 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 fi ve 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.
Item 4.01 Changes in Registrant’s Certifying Accountant
1. Please revise your Form 8-K to state whethe r KPMG LLP resigned, declined to stand for
re-election or was dismissed, as required by Item 304(a)(1)(i) of Regula tion S-K. It is not
sufficient to state that your board of di rectors “determined not to renew [y]our
engagement of KPMG LLP”, as that wording is unclear to a reader.
2. In your amended Form 8-K, include an updated Exhibit 16 letter from the former
accountant referencing th e revised Form 8-K.
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.
Mr. Steven Richards TTM Technologies, Inc. November 18, 2010 Page 2
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 me at (202) 551-3446 if you have questions.
Sincerely,
Jaime G. John Staff Accountant