SecProbe.io

September 6, 2013

Via E -mail
Todd B. Schull
Executive Vice President, Chief Financial Officer, Treasurer and Secretary
TTM Technologies, Inc.
1665 Scenic Avenue, Suite 250
Costa Mesa, California, 92626

Re: TTM Technologies, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2012
Filed March 1, 2013
Form 10 -Q for the Quarterly Period Ended July 1, 2013
Filed August 6, 2013
File No. 000 -31285

Dear Mr. Schull :

We have reviewed your filing an d 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 advising us when you will provide the 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 provide in
response to these comment s, we may have  additional comments.

Form 10 -K for the Fiscal Year Ended December 31, 2012

General

1. You disclose that you have customers in the Middle East.   Your website lists information
on “EMEA,” which we understand to mean Europe, the Middle East and Africa, regions
that include Syria and Sudan. We also note that your website includes a drop down m enu
for requesting a capabilities sheet that includes Syria and Sudan, and a drop down menu
for requesting a quote that includes Syria, Sudan and Cuba.  Syria, Sudan and Cuba are
identified by the State Department as state sponsors of terrorism and are sub ject to U.S.
economic sanctions and export controls.  Please describe to us the nature and extent of
your past, current, and anticipated contacts with Syria, Sudan and Cuba, whether through

Todd B. Schull
TTM Technologies, Inc.
September 6, 2013
Page 2

 subsidiaries, distributors, resellers or other direct or indirect arrangements, including
through Huawei and Ericsson, companies you list as two of your five largest customers.
According to recent news articles, Huawei does business in Syria.  According to publicly
available letters to the staff, Ericsson sells equipmen t and services in Syria, Sudan and
Cuba, and it has offices in those countries.  Your response should describe any services
or products you have provided to Syria, Sudan or Cuba, and any agreements, commercial
arrangements, or other contacts you have had w ith the governments of those countries or
entities controlled by those governments.

2. Please discuss the materiality of your contacts with Syria , Sudan and Cuba described in
response to the foregoing comment,  and whether those contacts constitute a material
investment risk for your security holders.  You should address materiality in quantitative
terms, including the approximate dollar amounts of any associated revenues, assets, and
liabilities for the last th ree fiscal years and the subsequent interim period .  Also, address
materiality in terms of qualitative factors that a reasonable investor would deem
important in making an investment decision, including the potential impact of corporate
activities upon a c ompany’s reputation and share value.  Various state and municipal
governments, universities, and other investors have proposed or adopted divestment or
similar initiatives regarding investment in companies that do business with U.S. -
designated state sponso rs of terrorism.  Your materiality analysis should address the
potential impact of the investor sentiment evidenced by such actions directed toward
companies that have  operations associated with Syria, Sudan and Cuba.

3. Please address the potential for repu tational harm from your relationships with Huawei
and Ericsson in light of their business in Syria, Sudan and Cuba, and in Iran, which also
is a U.S. -designated state sponsor of terrorism and is subject to U.S. economic sanctions
and export controls.  We n ote fr om Huawei’s website that it conducts business with
government -controlled Iranian companies, and we are aware of negative publicity,
including reports of negative statements by U.S. government officials, regarding the
nature of its business in Iran.  We note also that Ericsson’s 2012 Form 20 -F includes
disclosure that it has an office in Iran and it conducts business with government -
controlled Iranian companies.  We also are aware of negative publicity, including reports
of negative statements by U.S. government officials, regarding the nature of Ericsson’s
business in Iran.  In addition, we note 2012 news articles reporting that Ericsson’s
subsidiary in Panama paid a fine to the Department of Commerce for violating
restrictions on exports to Cuba.

4. We note disclosure on page 20 that your aerospace/defense sales are related to U.S. and
foreign military and defense programs, and on page 26, that some of the items you
manufacture are controlled for export by the Department of Commerce’s Bureau of
Industry and Security.  Please tell us whether any of your contacts with Syria, Sudan
and/or Cuba involve equipment, components or technologies that are dual use or are on
the Department of Commerce’s Commerce Control List.

Todd B. Schull
TTM Technologies, Inc.
September 6, 2013
Page 3

Form 10 -Q for the Quarterly Period E nded  July 1, 2013

Consolidated Condensed Statements of Operations, page 3

5. We note that you completed the sale of your controlling interest in Dongguan Shengyi
Electronics Ltd. (SYE) in June 2013.  Please tell us what consideration you gave to
reporting this sale as a discontinue d operation pursuant to ASC 205 -20-45.  As part of
your response, please tell us whether SYE was a component as described in ASC 205 -20-
20.

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, the y 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 the 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 proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Eiko Yaoita Pyles , Staff Accountant,  at (202) 551 -3587 or Christine
Davis, Assistant Chief Accountant, at (202) 551 -3408, if you have questions regarding
comments on the financial statements and re lated matters.  If you require further assistance, do
not hesitate to contact me at (202) 551 -3406 .

Sincerely,

 /s/ Patrick Gilmore

Patrick Gilm ore
Accounting Branch Chief