SecProbe.io

July 19, 2012

Via E -mail
Steven W. Richards
Executive Vice President , CFO and Secretary
TTM Technologies , Inc.
2630 South Harbor Boulevard
Santa Ana, California 92704

Re:  TTM Technologies, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2011
Filed February 29, 2012
File No. 000 -31285

Dear  Mr. Richards :

We have reviewed your filing an d have the following comments.  Please note that we
have limited our review to only your financial statements and related disclosures.  In some of our
comment s, 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 advising us when you will provide t he requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you pro vide in
response to these comment s, we may have  additional comments.

Form 10 -K for the Fiscal Year Ended December 31, 2011

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Poli cies and Estimates
Long -lived Assets, page 38
1. We note that during the year ended December  31, 2011, goodwill allocated to the N orth
America segment was impaired.  In future filings, t o the extent you perform two -step
impairment tests after performing quali tative analyses, and any of your reporting unit s
with goodwill are at risk of failing “step one” of ASC 350 -20-35-4 because the fair value

Steven W. Richards
TTM Technologies , Inc.
July 19, 2012
Page 2

 is not substantially in excess of the carrying value, please disclose the following
information:
 The percentage by w hich fair value exceeded carrying value as of the most recent
step-one test;
 Amount of goodwill allocated to the reporting unit;
 A description of the methods and key assumptions used and how the key assumptions
were determined;
 Analysis of the degree of uncertainty associated with your assumptions; and
 A description of potential events and/or changes in circumstances that could
reasonably be expected to negatively affect the key assumptions.

Alternatively, if in your view your reporting units are not a t risk we encourage you to
disclose that fact.

Liquidity and Capital Resources, page 44
2. We note that as of December  31, 2011, you had cash and cash equivalents of $70.4
million located in Asia.  Please clarify whether this amount is the total amount of c ash
held by foreign subsidiaries.  To the extent there is  cash and cash equivalents held by
subsidiaries located in foreign regions other than Asia ,  please  tell us and  disclose the
total amount of cash held by foreign subsidiaries in future filings.  Also , please tell us
what consideration was given to disclosing the potential income tax consequences of
repatriating  undistributed earnings of foreign subsidiaries.   Please refer to Item  303(a)(1)
of Regulation  S-K and Section  IV of SEC Release 33 -8350.

Notes to Consolidated Financial Statements

Note (2) Summary of Significant Accounting Policies

Revenue Recognition, page 70
3. We note from disclosure in the business section that you provide certain value -added
services as well as design and engineering  servi ces.  Please tell us whether these services
are separate deliverables in your arrangements with customers.  To the extent such
services constitute separate deliverables, please explain the terms of the arrangements
containing such services, how you allocat e arrangement consideration and how you
recognize revenue for the services.

Note (14) Commitments and Contingencies, page 96
4. We note your disclosure indicating that “the amount of any reasonably possible or
probable loss for known matters would not be ma terial to the Company’s financial
condition.”  Please tell us what consideration was given to disclosing whether such

Steven W. Richards
TTM Technologies , Inc.
July 19, 2012
Page 3

 matters may be material to your results of operations and cash flows or alternatively, your
financial statements as a whole. In this regar d, disclosing that a contingency is not
expected to be material to one but not all of your financial statements does not meet the
requirements of ASC 450 -20-50-4(b).

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of t he disclosure 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 procee ding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact David Edgar, Staff Accountant , at (202) 551 -3459  if you have questions
regarding comments on the financial statements and re lated matter s.  Please contact me at (202)
551-3406 with any other questions.

Sincerely,

 /s/ Patrick Gilmore

Patrick Gilmore
Accounting Branch Chief