SEC Comment Letter 0000000000-23-011793 to Shimmick Corp (SHIM)
Shimmick Corp
Date: Oct. 26, 2023 · CIK: 0001887944 · Accession: 0000000000-23-011793
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File numbers found in text: 333-274870
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United States securities and exchange commission logo
October 26, 2023
Steven Richards
Chief Executive Officer
Shimmick Corporation
530 Technology Drive
Suite 300
Irvine, CA 92618
Re:Shimmick Corporation
Amendment No. 1 to Registration Statement on Form S-1
Filed October 23, 2023
File No. 333-274870
Dear Steven Richards:
We have reviewed your amended registration statement and have the following
comments.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 registration statement and the information you
provide in response to this letter, we may have additional comments.
Amendment No. 1 to Registration Statement on Form S-1
Prospectus Summary
Our Projects, page 6
1.We note your revised disclosure on page 8. Please clarify the basis for the forecast that
$60 billion will be invested for water infrastructure per year.
Recent Developments, page 11
2.We note that you have attributed the expected net income for the three months ended
September 29, 2023, to be primarily driven by a significant gain on the sale of non-core
business contracts. Given the potentially significant gain on sale included in your
preliminary estimates, please explain to us how you determined your disclosure provides
investors sufficient information to understand your estimated results of operations.
FirstName LastNameSteven Richards
Comapany NameShimmick Corporation
October 26, 2023 Page 2
FirstName LastName
Steven Richards
Shimmick Corporation
October 26, 2023
Page 2
Specifically, please tell us how you considered the need to disclose the amount of the gain
recognized from the sale of non-core business contracts and/or a range of estimated
operating expenses.
Please contact Howard Efron at 202-551-3439 or Robert Telewicz at 202-551-3438 if
you have questions regarding comments on the financial statements and related matters. Please
contact Stacie Gorman at 202-551-3585 or Jeffrey Gabor at 202-551-2544 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Zachary Davis, Esq.