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Correspondence

Brandon Lombardi

Tel. 602.445.8335

Fax. 602.445.8679

LombardiB@gtlaw.com

August 12, 2010

VIA FEDERAL EXPRESS AND THE EDGAR SYSTEM

United States Securities and Exchange Commission

Mail Stop 4561

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:  Courtney Haseley

    Re:

     TTM Technologies, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2009

Filed March 15, 2010

Form 8-K/A Filed April 26, 2010

File No. 000-31285

Dear Ms. Haseley:

On behalf of our client, TTM Technologies, Inc. (the “Company”), we are responding to
comments provided by the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) by letter dated July 23, 2010 to Kenton K. Alder, Chief Executive Officer of the
Company. The Company’s responses to the Staff’s comments are indicated below, directly
following a restatement of each Staff comment in bold, italicized type. In this letter,
references to “we,” “us,” and “our” refer to the Company.

Form 10-K for the Fiscal Year Ended December 31, 2009

Item 1. Business

Customers and Markets, page 7

    1.

    Staff Comment: 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. government in your
customer discussion. Please also explain why you have not provided the disclosure
required by Item 101(c)(1)(ix) of Regulation S-K.

    Company Response: We respectfully advise the Staff that, while the U.S.
government is an end user of a significant portion of our products, the portion of our
business with the government involves indirect sales through OEMs and EMS resellers and
does not involve direct contracts with the government. Substantially all of our sales
to these OEMs and resellers are made through firm purchase orders, which are not
subject to cancellation, returns, or re-negotiation in the event that the federal end
user customer elects to renegotiate or terminate its direct contract with the reseller.
Our resellers therefore bear the risk of any renegotiation or termination by federal
end user customers. Accordingly, if the government chose to terminate its contracts with our resellers, the impact to our business would
be reflected as reduced demand from our customers. In the event that there are changes
in the manner in which we conduct business with the government, we will assess the
impact of these changes in light of Item 101(c)(1)(ix) of Regulation S-K and will
provide related disclosures in future filings as appropriate.

Securities and Exchange Commission

August 12, 2010

Page 2

    Notwithstanding the foregoing, in response to the Staff’s comment, we will revise the
customer discussion included in the Business section of future filings to clarify that
we are a supplier, primarily as a subcontractor, to the U.S. government, as discussed
in the risk factor referenced by the Staff in its comment. In addition, in future
filings we will revise that risk factor to clarify that the U.S. government is not a
direct customer of our company.

Suppliers, page 9

    2.

    Staff Comment: We note your disclosure in this section that “most of our raw
materials are generally available in the open market from numerous other potential
suppliers.” 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
issue to our letter dated May 30, 2008, in which we raised comments 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 sources of supply in
your backplane assembly business segment.

    Company Response: Pursuant to the Staff’s comment, we will include the
following disclosure in our future filings in order to discuss the use of raw materials
in our backplane assembly business segment, beginning with our Annual Report on Form
10-K for the fiscal year ending December 31, 2010:

    “Suppliers

    The primary raw materials we use in PCB manufacturing include copper-clad
laminate; chemical solutions such as copper and gold for plating
operations; photographic film; carbide drill bits; and plastic for
testing fixtures. Although we have preferred suppliers for some raw
materials used in the manufacture of printed circuit boards, most of our
raw materials are generally readily available in the open market from
numerous other potential suppliers.

    The primary raw materials we use in backplane assembly are manufactured
components such as PCBs, connectors, capacitors, resistors, diodes,
integrated circuits and formed sheet metal, many of which are custom made
and controlled by our customers’ approved vendors. These components for
backplane assemblies in some cases have limited or sole sources of
supply. For example, in some instances our customers will require us to
use a specific component from a particular supplier or require us to use
a component provided by the customer itself, in which case we may have a
single or limited number of suppliers for these specific components.

    We typically use just-in-time procurement practices to maintain our raw
materials inventory at low levels and work closely with our suppliers to
obtain technologically advanced raw materials. In addition, we
periodically seek alternative supply sources to ensure that we are
receiving competitive pricing and service. Adequate amounts of all raw
materials have been available in the past, and we believe this
availability will continue into the foreseeable future.”

Securities and Exchange Commission

August 12, 2010

Page 3

    We also advise the Staff that, as a result of our recent business combination with
Meadville, our backplane assembly business is not material to our results of operations
and is no longer a separate operating segment.

Backlog, page 9

    3.

    Staff Comment: During your May 6, 2010 earnings call, you disclosed a book to
bill ratio for printed circuit boards. However, in your Business section, 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 indication 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.

    Company Response: Pursuant to the Staff’s comment, we will disclose in our
future filings, beginning with our Annual Report on Form 10-K for the fiscal year
ending December 31, 2010, the dollar amount of backlog orders believed to be firm as of
year-end and as of the preceding year-end, together with the portion thereof that is
not reasonably expected to be filled within the following 12 months.

Item 1A. Risk Factors

Our results of operations are often subject to the demand fluctuations and seasonality...,
page 20

    4.

    Staff Comment: You indicate that you have “experienced sales fluctuations due
to seasonal patterns in the capital budgeting and purchasing cycle, as well 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 business 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

    Company Response: Prior to our 2006 acquisition of Tyco Printed Circuit
Group, we experienced sales fluctuations due to the seasonal patterns of our customers
and end markets. Our acquisition of Tyco Printed Circuit Group and our resulting entry
into the aerospace/defense market reduced these prior seasonal fluctuations in our
business. As a result, prior to the acquisition of the PCB business of Meadville, no
material portion of our business was considered to be seasonal. Following the
completion of our acquisition of the PCB business of Meadville, our business is again
subject to seasonal fluctuations. In particular, we expect to have higher net sales in
the third quarter as a result of end customer demand in anticipation of those
customers’ fourth quarter sales of consumer electronics products. Beginning with our
Quarterly Report on Form 10-Q for the quarterly period ended June 28, 2010, we will
address seasonality in our Management’s Discussion and Analysis of Financial Condition
and Results of Operations. In addition, beginning with our Annual Report on Form 10-K
for the fiscal year ending December 31, 2010, we will also address seasonality in our
Business section.

Securities and Exchange Commission

August 12, 2010

Page 4

Item 2. Properties, page 32

    5.

    Staff Comment: 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 Instruction 1 to
Item 102 of Regulation S-K.

    Company Response: Pursuant to the Staff’s comment, we will address the
suitability, adequacy, productive capacity and extent of utilization of our owned and
leased facilities in our future filings, beginning with our Annual Report on Form 10-K
for the fiscal year ending December 31, 2010.

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Overview, page 37

    6.

    Staff Comment: 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 financial 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 impact 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.

    Company Response: We respectfully advise the Staff that we believe that the
discussion in the “Overview” section identifies a number of significant matters with
which management is concerned in evaluating our financial condition and operating
results, including customer measurement and sales concentration.

    However, in light of Release No. 34-48960 and the Staff’s comment, we will include
additional disclosure in the “Overview” section of our Management’s Discussion and
Analysis of Financial Condition and Results of Operations in future filings, beginning
with our Quarterly Report on Form 10-Q for the period ended June 28, 2010, relating to
additional material operational risks and challenges facing our company and how
management has dealt or is dealing with these issues, particularly as a result of our
recent Meadville business combination.

Securities and Exchange Commission

August 12, 2010

Page 5

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.

    Staff Comment: We note in your disclosure here and in your schedule of
valuation and qualifying accounts on page 92 that you record inventory reserves 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 that 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 basis for your inventory and
why you believe including this reserve as a valuation and qualifying account is
appropriate.

    Company Response: We recognize that Note 6 to the consolidated financial
statements is presented as net of the reserve for excess and obsolete inventory, and
the related reserves are presented in Schedule II. However, the reserve for excess and
obsolete inventory is an accounting practice we use for record keeping purposes in
order to account for our inventory at the lower of cost or market. The application of
the reserve establishes a new cost basis for the applicable inventory. Therefore, as a
management tool, our practice is to establish a new cost basis on inventory as facts
and circumstances require through the application of our reserve for excess and
obsolete inventory methodology.

    Our methodology for calculating the reserve ensures that we maintain compliance with
the requirements of Chapter 4 footnote 2 of ARB 43 and SAB Topic 5BB. Our methodology
does not utilize any general reserve. Rather, reserves are only recorded against
specifically identified items, which are then tracked in accordance with the principles
of Chapter 4 footnote 2 of ARB 43 and SAB Topic 5BB. To accomplish this, we review
inventory each quarter and record specific reserves for inventory where the expected
utility of that inventory is less than the existing carrying basis, thereby creating a
new cost basis. Additionally, as part of the process we track inventory that
previously had a new cost basis established through the excess and obsolete inventory
reserve to ensure that it remains recorded at the new cost basis in future periods
until it is disposed.

    Going forward, we will continue to use our reserve methodology as a management tool for
record keeping purposes only and we will ensure in the presentation of inventory in our
financial statements and notes (e.g. Note 6) that inventory write downs to a new cost
basis are not characterized as an inventory reserve. In addition we will no longer
present an excess and obsolete reserve in Schedule II.

Securities and Exchange Commission

August 12, 2010

Page 6

Item 10. Directors, Executive Officers of the Registrant and Corporate Governance Matters
(Incorporated by Reference from Definitive Proxy Statement on Schedule 14A, filed April 12,
2010)

Committees of the Board of Directors, page 8

    8.

    Staff Comment: Please advise what consideration you gave to the requirements of
Item 407(c)(2)(vi) of Regulation S-K. You indicate that your nominating and corporate
governance committee considers diversity when recommending director nominees for election
and that the committee “evaluates its effectiveness in achieving diversity on the board
of directors through its annual review of board member composition, which identifies
ethnicity, gender, and industry experience.” In future filings, we would expect to see
more detailed disclosure with respect to how your nominating and corporate governance
committee considers diversity in identifying 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 description of how this policy is
implemented, as well as how the nominating and corporate governance committee assesses
the effectiveness of its policy.

    Company Response: In response to the Staff’s comment and in light of Item
407(c)(2)(vi) of Regulation S-K, we will include the following disclosure in future
filings, beginning with our Annual Report on Form 10-K for the fiscal year ending
December