SecProbe.io

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 April 3, 2025

Daniel Boehle
Chief Financial Officer
TTM Technologies, Inc.
200 East Sandpointe
Suite 400
Santa Ana CA 92707

 Re: TTM Technologies, Inc.
 Form 10-K for the year ended December 30, 2024
 File No. 0-32185
Dear Daniel Boehle:

 We have completed our review of your filing. We remind you that the
company and
its management are responsible for the accuracy and adequacy of their
disclosures,
notwithstanding any review, comments, action or absence of action by the staff.

 Sincerely,

 Division of Corporation
Finance
 Office of Manufacturing
</TEXT>
</DOCUMENT>

CORRESP
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 Response Letter

 CORRESPONDENCE
 TTM Technologies, Inc .
 Global Headquarters (HQ)
 200 East Sandpointe , Suite 400
 Santa Ana, CA 92707, USA
 Tel +1.714.327.3000
 www.ttm.com
 March 28, 2025
 VIA EDGAR Office of Manufacturing
 Division of Corporation Finance U.S. Securities and Exchange
Commission 100 F Street, N.E. Washington, D.C. 20549
 Attention: Charles Eastman and Claire Erlanger

 Re:
 TTM Technologies, Inc.
 Form 10-K for the fiscal year ended December 30, 2024
 Filed February 21, 2025
 File No. 000-31285
 Dear Mr. Eastman and Ms. Erlanger: TTM
Technologies, Inc. (“TTM”, “we” or the “Company”) is writing in response to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in its
letter to the Company dated March 19, 2025 (the “Comment Letter”), relating to the Company’s Annual Report on Form 10-K for the fiscal year ended December 30, 2024, filed with the
Commission on February 21, 2025. The Staff’s comments included in the Comment Letter, together with the Company’s
responses, are set forth below. The following headings and numbered paragraphs of this letter correspond to the headings and numbered paragraphs of the Comment Letter.
 Management’s Discussion and Analysis of Financial Condition and Results of Operations
 Results of Operations, page 45

 1.
 We note that you discuss your results of operations on a segment basis in terms of net sales and gross
margin. Please explain to us what consideration you gave to discussing the change in segment operating income, your segment profitability measure disclosed in the notes to the financial statements, as part of your MD&A discussion. See guidance
in Item 303(b) of Regulation S-K. The Company acknowledges the Staff’s
comment. We respectfully advise the Staff that, in preparing the MD&A, we considered the usefulness of the information to investors and other users of our financial statements. As a significant portion of our operating expenses are fixed in
nature, the operational drivers of segment results are consistent at the gross profit/margin and operating income/margin level. Additionally, both of these measures of operational performance are reviewed by the chief operating decision maker
(“CODM”). However, to promote further consistency between the MD&A and the segment disclosure in the notes to the financial
statements in accordance with the guidance in Item 303(b) of Regulation S-K, we respectfully propose to the Staff that our future filings will incorporate in the MD&A results of operations a discussion and
analysis of the changes in segment operating income/margin, beginning with our next Form 10-Q filing for the first quarter of 2025.
 Page | 1

 TTM Technologies, Inc .
 Global Headquarters (HQ)
 200 East Sandpointe , Suite 400
 Santa Ana, CA 92707, USA
 Tel +1.714.327.3000
 www.ttm.com
 Notes to the Consolidated Financial Statements
 Segment Information, page 85

 2.
 Please refer to the reconciliation of net sales to segment operating income. Please tell us whether
operating expenses represents a significant segment expense determined in accordance with ASC 280-10-50-26A or if it represents
“other segment items” in accordance with ASC 280-10-50-26B. If the amount represents other segment items, please tell
us how you complied with the guidance in ASC 280-10-50-26B, including disclosure of a qualitative description of the composition
of other segment items. Please advise. The Company acknowledges the Staff’s comment. We respectfully advise
the Staff that the operating expenses disclosed in the reconciliation of net sales to segment operating income represent a significant segment expense determined in accordance with ASC
 280-10-50-26A, as it is regularly provided to the CODM.

 3.
 We note your disclosure of “other profit or (loss)” in your reconciliation of total segment
operating income to consolidated income before taxes. We also note from footnote (1) that this amount represents elimination of inter-segment sales, accelerated depreciation associated with plant closures, gain on sale of assets, unrealized
gain/loss on commodity hedge, acquisition costs, non-cash goodwill impairment charge, restructuring, and purchase accounting related inventory markup. In light of the significance of this amount in each year
presented, we believe that you should separately disclose all significant amounts in accordance with ASC 280-10-50-31. Please
revise future filings accordingly. The Company acknowledges the Staff’s comment. We respectfully advise the
Staff that we will revise our future filings to separately disclose any significant amounts, beginning with our next Form 10-Q filing for the first quarter of 2025.
 * * * * We acknowledge the
Staff’s reminder in the Comment Letter that the Company and its management are responsible for the adequacy and accuracy of their disclosures, notwithstanding any review, comments, action or absence of action by the Staff.
 We believe that we have adequately responded to the Staff’s comments included in the Comment Letter. If you have any questions regarding
the responses contained in this letter, please do not hesitate to contact the undersigned at 714-327-3000.

 Sincerely,

 /s/ Daniel L. Boehle

 Daniel L. Boehle

 Executive Vice President and Chief Financial Officer

 Page | 2

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 March 19, 2025

Daniel Boehle
Chief Financial Officer
TTM Technologies, Inc.
200 East Sandpointe
Suite 400
Santa Ana CA 92707

 Re: TTM Technologies, Inc.
 Form 10-K for the year ended December 30, 2024
 File No. 0-32185
Dear Daniel Boehle:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the year ended December 30, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 45

1. We note that you discuss your results of operations on a segment basis
in terms of net
 sales and gross margin. Please explain to us what consideration you gave
to
 discussing the change in segment operating income, your segment
profitability
 measure disclosed in the notes to the financial statements, as part of
your MD&A
 discussion. See guidance in Item 303(b) of Regulation S-K.
Notes to the Consolidated Financial Statements
Segment Information, page 85

2. Please refer to the reconciliation of net sales to segment operating
income. Please tell
 us whether operating expenses represents a significant segment expense
determined in
 accordance with ASC 280-10-50-26A or if it represents "other segment
items" in
 accordance with ASC 280-10-50-26B. If the amount represents other
segment items,
 March 19, 2025
Page 2

 please tell us how you complied with the guidance in ASC 280-10-50-26B,
including
 disclosure of a qualitative description of the composition of other
segment items.
 Please advise.
3. We note your disclosure of "other profit or (loss)" in your
reconciliation of total
 segment operating income to consolidated income before taxes. We also
note from
 footnote (1) that this amount represents elimination of inter-segment
sales, accelerated
 depreciation associated with plant closures, gain on sale of assets,
unrealized gain/loss
 on commodity hedge, acquisition costs, non-cash goodwill impairment
charge,
 restructuring, and purchase accounting related inventory markup. In
light of the
 significance of this amount in each year presented, we believe that you
should
 separately disclose all significant amounts in accordance with ASC
280-10-50-31.
 Please revise future filings accordingly.
 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Charles Eastman at 202-551-3794 or Claire Erlanger at
202-551-3301
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

October 4, 2019
Todd B. Schull
Executive Vice President and Chief Financial Officer
TTM Technologies, Inc.
200 East Sandpointe
Suite 400
Santa Ana, CA 92707
Re:TTM Technologies, Inc.
Form 10-K for Fiscal Year Ended December 31, 2018
Filed February 26, 2019
File No. 000-31285
Dear Mr. Schull:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Technology

CORRESP
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CORRESP

 September 24, 2019

Via EDGAR

 Brittany Ebbertt

Senior Staff Accountant

 Office of Information Technologies and
Services

 Division of Corporate Finance

 United States
Securities and Exchange Commission

 100 F Street, NE

Washington, D. C 20549

RE:
 TTM Technologies, Inc.

 Form 10-K for the fiscal year ended December 31, 2018

 Filed February 26, 2019

 File No. 000-31285

Dear Ms. Ebbertt:

 TTM Technologies, Inc., a Delaware
corporation (referred to as the “Company”, “we”, “our” or “us”), hereby submits its responses to the comments received from the Division of Corporation Finance of the Securities and Exchange Commission (the
“Commission”) dated September 6, 2019 relating to the Company’s Form 10-K for the fiscal year ended December 31, 2018 filed February 26, 2019 (the “Form 10-K”). For the convenience of the staff of the Commission (the “Staff”), the Commission’s comments have been stated below in their entirety, with the Company’s response to a particular
comment set out immediately underneath it. The headings and numbered paragraphs in this letter correspond to the headings and numbered paragraphs in the comment letter from the Staff.

Form 10-K for Fiscal Year Ended December 31, 2018

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Results of Operations

 Gross Margin, page 42

Staff Comment:

1.
 We note your disclosure and quantification of capacity utilization. Please revise to describe how this measure
is calculated and expand the discussion to include the underlying reasons for any significant fluctuations in the measure from period-to-period. Please provide revised
draft disclosures in your response. Refer to Item 303(a)(3) of Regulation S-K.

 Company
Response:

 The Company acknowledges the Staff’s comment requesting a description of how capacity utilization is calculated. The Company advises
the Staff that we calculate the capacity utilization percentage rate by calculating the actual production in a given period and dividing it by the maximum potential output if capacity was fully used. The Company will include this calculation in
future filings with the Commission. Please see the example of our proposed disclosure at the end of this response.

 As to the Staff’s request to
expand our disclosure to include the underlying reasons for any significant fluctuations in the measure from period-to-period, the Company advises the Staff that, with
respect to the

current discussion of capacity utilization in the Form 10-K, capacity utilization in our Asia PCB facilities was 75% and 86% for each of the respective
years ended December 31, 2018 and January 1, 2018. The decline in capacity utilization in our Asia PCB facilities was due to a decrease in sales in the Cellular Phone and Automotive end markets. Capacity utilization in our North America
PCB facilities was 60% and 54% for the respective years ended December 31, 2018 and January 1, 2018. The increase in capacity utilization in our North America PCB facilities was due to an increase in sales in the Aerospace & Defense
end market. The Company notes for the Staff that the Company began including a discussion of the reasons as to significant fluctuations in capacity utilization in the Company’s Form 10-Q for the quarterly
period ended April 1, 2019. The Company will continue such disclosure for significant fluctuations in future filings.

 As an example of our proposed
disclosure to be included in future filings, below is the capacity utilization discussion in the “Results of Operation — Gross Margin” section of Management’s Discussion and Analysis of Financial Condition and Results of
Operations in the Form 10-K, which we have revised to incorporate the above discussion (additions in bold and underlined):

“Capacity utilization is a key driver for us, which is measured by the actual production as a percentage of maximum capacity. This measure
is particularly important in our high volume Asia facilities, as a significant portion of our operating costs are fixed in nature. Capacity utilization for the year ended January 1, 2018 in our Asia and North America PCB
facilities was 86% and 54%, respectively, compared to 75% and 60%, respectively, for the year ended December 31, 2018. The decline in capacity utilization in our PCB facilities in Asia was due to a decrease in sales in the Cellular Phone
and Automotive end markets. The increase in capacity utilization in our North America PCB facilities was due to an increase in sales in the Aerospace & Defense end market.”

Notes to Consolidated Financial Statements

 (1) Nature
of Operations and Summary of Significant Accounting Policies Revenue Recognition, page 66

 Staff Comment:

2.
 You disclose you have long term contracts which service the aerospace and defense electronic market that you
account for using the percentage of completion method. Please revise to include terms and methodologies used in this policy that comply with ASC 606, and tell us whether this policy is consistent with your policy in accounting for your PCB
arrangements. Also, further clarify in your disclosures any significant differences between these long term contracts and the PCB arrangements. Please include revised draft disclosure in your response.

Company Response:

 The Company acknowledges the
Staff’s comment regarding the Company’s disclosure of long term contracts which service the aerospace and defense electronic market that are accounted for using the percentage of completion method. The Company advises the Staff that its
current disclosure addresses long term contracts separate from PCB arrangements in order to distinguish between short-term and long-term circumstances. In light of the Staff’s comment, however, the Company believes combining the disclosure will
more clearly describe the terms and methodologies applicable to our long term contracts and their compliance with ASC 606, Revenue from Contracts with Customers (“ASC 606”). To that point, the Company further advises the Staff that
revenue, whether pursuant to our long term contracts or our PCB arrangements, is recognized on a “cost-to-cost” percentage of completion basis as the services
are performed. The Company evaluated its long term contracts and determined over time revenue recognition

is appropriate in accordance with ASC 606, as the Company’s performance does not create an asset with an alternative use to the Company and has an enforceable right to payment for
performance completed to date. This policy is consistent with the Company’s accounting policy for PCB arrangements. As a result, there are no significant differences between our long term contracts and our PCB arrangements.

The Company will modify its disclosure in future filings as follows (additions in bold and underlined and deletions in
strikethrough):

 “Revenue Streams

For the PCBs and custom electronic assemblies, including pursuant to our long-term contracts related to the manufacture
of components, assemblies and subsystems, orders for products generally correspond to the production schedules of the Company’s customers and are supported with firm purchase orders. The Company’s customers have continuous control
of the work in progress and finished goods throughout the PCB and custom electronic assemblies manufacturing process, as PCBs these are built to customer specifications with no alternative use, and there
is an enforceable right to payment for work performed to date. As a result, beginning in the first quarter of 2018, the Company now recognizes began recognizing revenue over time based on the extent of progress towards
completion of the performance obligation. Revenue recognized under these contracts is based on the cost-to-cost method as it best depicts the transfer
of control to the customer which takes place as we incur costs. Under the cost-to-cost measure of progress, the extent of progress toward completion is measured based on
the ratio of costs incurred to date to the total estimated costs at completion of the performance obligation. Revenues are recorded proportionally as costs are incurred.

Additionally, the Company has certain long-term contracts related to its manufacture of components, assemblies, and subsystems which
service the aerospace and defense electronics market. These long-term contracts, many of which provide for periodic payments, are recognized over time under the percentage-of completion method. Estimated
manufacturing cost-at-completion for these contracts are reviewed on a periodic basis, and adjustments are made as needed to the estimated
cost-at-completion, based on actual costs incurred, progress made, and estimates of costs required to complete the contractual requirements. When the estimated
manufacturing cost-at-completion exceeds the contract value, the contract is written down to its net realizable value and the loss resulting from the cost overruns are
immediately recognized.

 FinallyIn addition, the Company manufactures components, assemblies, and
subsystems which service its wireless communications customers. The Company recognizes revenue at a point in time upon transfer of control of the products to the customer. Point in time recognition was determined as the customer does not
simultaneously receive or consume the benefits provided by the Company’s performance and the asset being manufactured has alternative uses to the Company.”

*            *
 *            *

 If you have any questions regarding the responses contained in this
letter, please do not hesitate to contact the undersigned at 714-327-3000.

Sincerely,

/s/ Todd B. Schull

Executive Vice President and Chief Financial Officer

CORRESP
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CORRESP

 September 12, 2019

Via EDGAR

 Brittany Ebbertt

Senior Staff Accountant

 Office of Information Technologies and
Services

 Division of Corporate Finance

 United States
Securities and Exchange Commission

 100 F Street, NE

Washington, D. C 20549

RE:
 TTM Technologies, Inc.

 Form 10-K for the fiscal year ended December 31, 2018

 Filed February 26, 2019

 File No. 000-31285

Dear Ms. Ebbertt:

 We have received the comment letter of
the Staff (the “Staff”) of the Securities and Exchange Commission dated September 6, 2019 sent to Todd B. Schull, Executive Vice President and Chief Financial Officer of TTM Technologies, Inc. (the “Company”) concerning the
Company’s above referenced Form 10-K. The comment letter asks for the Company’s written response within 10 business days or to advise the Staff when the Company will provide the Staff with its
response.

 By way of this letter, the Company confirms our conversation on September 11, 2019 regarding the Company’s request for
an extension of an additional 10 business days to complete the Company’s response. As discussed, the Company intends to provide its response to the comment letter by no later than October 4, 2019.

Please do not hesitate to call me at (714) 327-3013 if you have any questions or would like any additional
information.

Best Regards,

/s/ Tony Sanchez

Tony Sanchez

Vice President and Controller

TTM Technologies, Inc.

 cc: Todd B. Schull, Executive Vice President and Chief Financial Officer

September 6, 2019
Todd B. Schull
Executive Vice President and Chief Financial Officer
TTM Technologies, Inc.
200 East Sandpointe
Suite 400
Santa Ana, CA 92707
Re:TTM Technologies, Inc.
Form 10-K for Fiscal Year Ended December 31, 2018
Filed February 26, 2019
File No. 000-31285
Dear Mr. Schull:
            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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2018
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Gross Margin, page 42
1.We note your disclosure and quantification of capacity utilization.  Please revise to
describe how this measure is calculated and expand the discussion to include the
underlying reasons for any significant fluctuations in the measure from period-to-period.
Please provide revised draft disclosures in your response. Refer to Item 303(a)(3) of
Regulation S-K.

 FirstName LastNameTodd B. Schull
 Comapany NameTTM Technologies, Inc.
 September 6, 2019 Page 2
 FirstName LastName
Todd B. Schull
TTM Technologies, Inc.
September 6, 2019
Page 2
Notes to Consolidated Financial Statements
(1) Nature of Operations and Summary of Significant Accounting Policies
Revenue Recognition, page 66
2.You disclose you have long term contracts which service the aerospace and defense
electronic market that you account for using the percentage of completion method.  Please
revise to include terms and methodologies used in this policy that comply with ASC 606,
and tell us whether this policy is consistent with your policy in accounting for your PCB
arrangements.  Also, further clarify in your disclosures any significant differences
between these long term contracts and the PCB arrangements.  Please include revised
draft disclosure in your response.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Brittany Ebbertt, Senior Staff Accountant, at 202-551-3572 or Melissa
Kindelan, Senior Staff Accountant, at 202-551-3564 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services

September  20, 2017

Todd B. Schull
Executive Vice President and Chief Financial  Officer
TTM Technologies, Inc.
1665 Scenic Avenue, Suite 250
Costa Mesa, CA 92626

Re: TTM Technologies, Inc.
 Form 10 -K for the fiscal year ended January  2, 201 7
Filed February 24, 2017
File No. 000-31285

Dear M r. Schull :

We have completed our review of your filings .  We remind you that the company and its
management are responsible for the accuracy and adequacy of the ir disclosure s, notwithstanding
any review, comments, action or absence  of action  by the staff .

Sincerely,

 /s/  Kathleen Collins

Kathleen Collins
Accounting Branch Chief
Office of Information Technologies
and Services

cc: Tony Sanchez, Corpor ate Controller

CORRESP
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CORRESP

 FOIA Confidential Treatment Requested by TTM Technologies, Inc.

September 7, 2017

 VIA EDGAR

Kathleen Collins

 Accounting Branch Chief

Office of Information Technologies and Services

 Division of
Corporate Finance

 United States Securities and Exchange Commission

100 F Street, NE

 Washington, D. C 20549

RE:
TTM Technologies, Inc.

 Form 10-K for the
fiscal year ended January 2, 2017

 Filed February 24, 2017

Form 8-K furnished August 2, 2017

File No. 000-31285

Dear Ms. Collins:

 TTM Technologies, Inc., a Delaware
corporation (referred to as the “Company”, “we”, “our” or “us”), hereby submits its responses to the comments received from the Division of Corporation Finance of the Securities and Exchange Commission (the
“Commission”) dated August 10, 2017 relating to the Company’s Form 10-K for the fiscal year ended January 2, 2017 filed February 24, 2017 (the “Form 10-K”) and the Company’s Form 8-K furnished August 2, 2017. For the convenience of the staff of the Commission (the “Staff”), the Commission’s
comments have been stated below in their entirety, with the Company’s response to a particular comment set out immediately underneath it. The headings and numbered paragraphs in this letter correspond to the headings and numbered paragraphs in
the comment letter from the Staff.

 Due to the commercially sensitive nature of certain information contained herein, the Company has filed a separate
letter (the “Request Letter”) with the Staff requesting confidential treatment of the portions of this letter bracketed below pursuant to Rule 83 of the Commission’s Rules on Information and Requests (17 C.F.R. § 200.83)
(“Rule 83”). For the Staff’s reference, the Company has enclosed with the Request Letter an unredacted copy of this letter marked to show the portions redacted from the version filed via EDGAR and for which the Company is requesting
confidential treatment.

 In accordance with Rule 83, the Company requests confidential treatment of the highlighted and bracketed portions (the
“Confidential Material”) of this response letter.

 TTM-001

*** - Information omitted and provided under separate cover to the Staff pursuant to Rule 83.

 FOIA Confidential Treatment Requested by TTM Technologies, Inc.

Please promptly inform the following person of any request for disclosure of the Confidential Material made pursuant to the Freedom of Information Act or otherwise so that the undersigned may
substantiate the foregoing request for confidential treatment in accordance with Rule 83:

 TTM Technologies, Inc.

1665 Scenic Avenue, Suite 250,

 Costa Mesa, CA 92626

Attention: General Counsel

 Telephone: (714) 327-3000

 Form 10-K for the fiscal year ended January 2,
2017

 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 42

1.
We note your reference, both in your risk factor disclosures and on your earnings calls, to the impact of capacity utilization rates on your financial condition and results of operations. To the extent that utilization
rates is a key performance indicator use in managing your business, please include a discussion of this measure along with comparative period amounts or explain why you do not believe this disclosure is necessary. Refer to Section III.B.1 of SEC
Release No. 33-8350.

 Company Response:

The Company acknowledges the Staff’s comment regarding the Company’s disclosure of capacity utilization rates in our risk factors and earnings calls,
and whether a discussion of capacity utilization rates along with comparative period amounts should be included in Management’s Discussion and Analysis of Financial Condition and Results of Operations of our Form
10-K (“MD&A”). The Company respectfully submits that a discussion of capacity utilization rates as a driver of our business is already included in our MD&A. The Company directs the
Staff’s attention to the “Financial Overview” section of our MD&A on page 43 of our Form 10-K in which we explained that the increased demand we experienced during fiscal year 2016
“…resulted in higher capacity utilization at our Automotive focused facilities resulting in higher gross margins.” The Company further directs the Staff’s attention to the “Results of Operations – Gross Margins”
section on page 48 and 49 of our Form 10-K in which we noted that the increase in gross margin we experienced in our PCB operating segment from fiscal year 2015 to fiscal year 2016 was due, among other
drivers, to “…higher utilization and full year contribution from the Automotive focused facilities….” Similarly, we explained that the increase in our gross margin from fiscal 2014 to fiscal 2015 was primarily due to
“…higher utilization at our advanced technology plants….”

 TTM-002

*** - Information omitted and provided under separate cover to the Staff pursuant to Rule 83.

 FOIA Confidential Treatment Requested by TTM Technologies, Inc.

 In light of the Staff’s comment, however, the Company will include capacity utilization rates for each
applicable comparative period in future filings in which capacity utilization rate is discussed.

 Notes to the Consolidated Financial Statements

 Note 12. Fair Value Measures, page 98

2.
We note your reference to $13.5 million of derivative transaction gains included in fiscal 2016 earnings as well as amounts related to cash flow hedges reflected in other comprehensive income. Please tell us the
extent to which you continue to use derivative financial statements for risk management purposes and if material, revise to include the disclosures required by ASC
815-10-50.

 Company Response:

The Company acknowledges the Staff’s comment regarding the Company’s disclosure of $13.5 million of derivative transaction gains. The Company
respectfully submits that, as disclosed in the “Other Income (Expense)” subsection of the MD&A on page 50 of our Form 10-K, such amount relates to both foreign currency gains, as well as
derivative transaction gains. Further, the Company advises the Staff that the derivative impact was approximately $30,000 of the total referenced amount. Accordingly, the Company determined its use of derivatives to be immaterial for purposes of ASC
815-10-50 and therefore did not merit further disclosure in the Form 10-K.

The Company further advises the Staff that from time to time, it enters into foreign currency forward contracts to mitigate the impact of changes in foreign
currency exchange rates. Specifically, the Company’s foreign subsidiaries at times purchase forward exchange contracts to manage their foreign currency risks in relation to certain purchases of machinery denominated in foreign currencies other
than our foreign functional currency.

 The Company designates certain of these foreign exchange contracts as cash flow hedges. To ensure the adequacy and
effectiveness of our foreign exchange hedge positions, the Company continually monitors its foreign exchange forward positions, both on a stand-alone basis and in conjunction with their underlying foreign currency exposures, from an accounting and
economic perspective.

 As of July 3, 2017, our most recent quarter, the fair value of all open derivative assets and liabilities was approximately
$109,000 and $101,000, respectively. Additionally, for the quarter and two quarters ended July 3, 2017, the Company recognized net losses related to derivative transactions of approximately $176,000 and $30,000, respectively. The Company does
not believe the fair value of open derivatives nor the derivative transaction losses is material to its consolidated financial statements as of and for the quarter and two quarters ended July 3, 2017. The Company will continue to evaluate its
use of derivatives, and if such use becomes material, the Company will include appropriate disclosure in future filings as required by ASC 815-10-50.

TTM-003

 *** -
Information omitted and provided under separate cover to the Staff pursuant to Rule 83.

 FOIA Confidential Treatment Requested by TTM Technologies, Inc.

 Note 18. Segment Information, page 106

3.
We note that your PCB reportable segment is comprised of multiple, aggregated operating segments. Please tell us the operating segments that are aggregated into the PCB reportable segment and explain how you applied the
guidance in ASC 280-10-50-11(a) to (e) when determining that these various operating segments qualified for aggregation into
one reportable segment. If there are any differences in your operating segments, tell us why you determined that disaggregation was not warranted.

Company Response:

 The Company additionally advises the
Staff that our operating segments that are aggregated into the Printed Circuit Board (“PCB”) reportable segment are:

•

Aerospace & Defense/Specialty (“A&D”)

•

Automotive & Medical Industrial & Instrumentation (“AMI&I”)

•

Communications & Computing (“C&C”)

 The Company manufactures multi-layer PCBs on a low-volume, quick-turn basis, as well as on a high-volume production basis. We are primarily a contract manufacturer that produces customer-specific PCBs. To that end, we believe the use of separate PCB operating
segments allows us to better align with our end customers and markets. However, the Company ultimately decides where the customer-ordered products will be produced based on available capacity, facility capabilities, and facility qualification
requirements. As a result, customer orders can be produced at different facilities or PCB operating segments if all factory qualification requirements are met.

We applied the guidance in ASC
280-10-50-11(a) to (e) as outlined below:

PCB Reportable Segment – Aggregation Analysis

Economic Criteria

 Management determined that long-term
average gross margins were the key economic factor in the consideration of similar economic characteristics. Gross margins for each operating segment have historically had variability due to fixed operating costs and business cycles, with variation
also driven by volume, plant performance, and product mix. The A&D, C&C, and AMI&I operating segments have similar long-term average gross margins. The Company is a contract manufacturer and product pricing follows the same process
irrespective of the operating segment. The Company’s historical average gross margins and expected future gross margins for the PCB operating segments would be within a range of [***] to [***].

Based on the analysis above management concluded the PCB operating segments have similar economic characteristics.

TTM-004

 *** -
Information omitted and provided under separate cover to the Staff pursuant to Rule 83.

 FOIA Confidential Treatment Requested by TTM Technologies, Inc.

 Similar in Following Areas

a.
Nature of the products and services

 The A&D, C&C, and AMI&I operating segments provide the same
products and services. The value chain of manufacturing electrical equipment is outlined below:

 The A&D, C&C, and AMI&I operating segments are in the initial or intermediate manufacturing step (the first two
boxes above) of the manufacturing equipment value chain where raw materials are transformed into printed circuit boards. The PCB end product is not usable unless it undergoes further component loading and system integration. The size of the products
range from small to mid-size and have low weight per unit. All the operating segments produce only one type of product (PCBs) which can be manufactured at any of the operating segments.

b.
Nature of Production Processes – the A&D, C&C, and AMI&I operating segments operate the same processes and functions.

All PCBs are processed using similar equipment and processes. PCB manufacturing uses a wet process with chemicals to produce PCBs. Manufacturing is
process-driven, and the primary drivers include labor efficiency, yield performance, and scrap reduction. Although the A&D, C&C, and AMI&I operating segments can have production differences due to customer preferences, specific requests,
and historical relationships, and some specialization in the plants, customer orders for most products can be processed from any of our operating segments because each operating segment has the same core processes. Moreover, the A&D, C&C,
and AMI&I operating segments supply PCBs to customers who have similar PCB needs in the electronic equipment industry.

c.
Type or Class of Customer – The A&D, C&C, and AMI&I operating segments’ customers are OEMs who utilize the product as a component in the final manufacturing of their end-products. We sell directly to the OEMs or to their EMS providers who purchase on their behalf from our operating segments.

d.
Nature of distribution – The A&D, C&C, and AMI&I operating segments ship to our OEM customers or their EMS providers utilizing air freight, ground or ocean transport.

e.
Regulatory requirements – The A&D, C&C, and AMI&I operating segments adhere to similar local environmental regulations, including air quality and discharge regulations.

TTM-005

 *** -
Information omitted and provided under separate cover to the Staff pursuant to Rule 83.

 FOIA Confidential Treatment Requested by TTM Technologies, Inc.

 Based on the analysis above, management concluded that the A&D, C&C, and AMI&I operating segments
are similar. As such, the A&D, C&C, and AMI&I segments were aggregated into a single reportable operating segment, the PCB reportable operating segment, in accordance with the guidance in ASC 280-10-50-11(a) to (e).

 Form
8-K furnished August 2, 2017

 Business Outlook

4.
Please revise to include a quantitative reconciliation of your non-GAAP guidance measures to the most directly comparable GAAP measure, or include a statement that such
reconciliation is not practicable without unreasonable effort. Refer to guidance in Item 10(e)(1)(i)(B) of Regulation S-K and Question 102.10 of the Non-GAAP Compliance
Disclosure and Interpretations issued May 17, 2016.

 Company Response:

The Company acknowledges the Staff’s comment regarding its use of non-GAAP forward looking information in our
earnings guidance, namely the Company’s forecasted non-GAAP net income attributable to stockholders per diluted share (the “Non-GAAP Measure”) for the
third quarter of 2017. The Company additionally advises the Staff that the financial measure calculated and presented in accordance with U.S. GAAP most directly comparable to the Non-GAAP Measure is net income
attributable to stockholders per diluted share. The Company further notes that the timing and amount of certain items the Company excludes from its Non-GAAP Measure, such as restructuring actions, impairment
charges, unusual gains and losses, and tax adjustments, are highly variable and difficult to predict due to various factors outside of management’s control and could have a material impact on the GAAP reported results for the applicable
guidance period. Accordingly, the Company was unable to provide a reconciliation of its Non-GAAP Measure to net income attributable to stockholders per diluted share, on a forward-looking basis, without
unreasonable efforts. In an effort to provide investors with transparency on the operations of the business and a method for investors to measure the Company’s performance period-over-period and to anticipate financial performance in future
periods, and further given the inherent uncertainties in forecasting GAAP net income attributable to stockholders per diluted share, the Company determined to provide the Non-GAAP Measure it had available in
lieu of providing no future guidance.

 In future filings with the Commission in which the Company provides the
Non-GAAP Measure, the Company will modify its disclosure to explain that a quantitative reconciliation cannot be provided without unreasonable effort, and will identify the information that is unavailable and
the probable significance of such unavailable information, all in a manner substantially similar to our discussion in the paragraph above an

CORRESP
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CORRESP

 August 15, 2017

Via EDGAR

 Kathleen Collins

Accounting Branch Chief

 Office of Information Technologies and
Services

 Division of Corporate Finance

 United States
Securities and Exchange Commission

 100 F Street, NE

Washington, D. C 20549

RE:
TTM Technologies, Inc.

Form 10-K for the fiscal year ended January 2, 2017

Filed February 24, 2017

Form 8-K furnished August 2, 2017

File No. 000-31285

 Dear Ms. Collins:

We have received the comment letter of the Staff (the “Staff”) of the Securities and Exchange Commission dated August 10, 2017 concerning TTM
Technologies, Inc.’s (the “Company”) above referenced Form 10-K and Form 8-K. The comment letter asks for the Company’s written response within 10 business days or to advise the Staff when the Company will provide the Staff with
its response.

 By way of this letter, the Company confirms the conversation between Brittany Ebbertt, Staff Accountant and Tony Sanchez, Corporate
Controller on August 11, 2017 regarding the Company’s request for an extension of an additional 10 business days to complete the Company’s response. As discussed, the Company intends to provide its response to the
comment letter by no later than September 8, 2017.

 Please do not hesitate to call me at (714) 327-3079 if you have any questions or would like
any additional information.

Best Regards,

/s/ Todd B. Schull

Todd B. Schull

Executive Vice President and Chief Financial Officer

TTM Technologies, Inc.

 cc: Tony Sanchez, Corporate Controller

August  10, 2017

Todd B. Schull
Executive Vice President and Chief Financial  Officer
TTM Technologies, Inc.
1665 Scenic Avenue, Suite 250
Costa Mesa, CA 92626

Re: TTM Technologies, Inc.
 Form 10 -K for the fiscal year e nded January  2, 201 7
Filed February 24, 201 7
Form 8 -K furnished August 2, 2017
File No. 000-31285

Dear M r. Schull :

We have limited our review  of your filing s to the financial statements and related  disclosures
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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Form 10 -K for the fiscal year ended January 2, 2017

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 42

1. We note your reference, both in your risk factor disclosures and on your earnings calls, to the
impact of  capacity utilization rates on your financial condition and results of operations.  To the
extent that utilization rates is a key performance indicator use in managing your business,
please include a discussion of this measure along with comparative period  amounts or explain
why you do not believe this disclosure is necessary.  Refer to Section III.B.1 of SEC Release
No. 33 -8350.

Notes to the Consolidated Financial Statements

Note 12. Fair Value Measures, page 98

2. We note you r reference to $13.5 million of derivative transaction gains included in fiscal 2016
earnings as well as amounts related to cash flow hedges reflected in other comprehensive

Todd B. Schull
TTM Technologies, Inc.
August  10, 2017
Page 2

 income.   Please tell us the extent to which you continue to use derivative financial instruments
for risk mana gement purposes and if material, revise to include the disclosures required by
ASC 815 -10-50.

Note 18. Segment Information, page 106

3. We note that your PCB reportable segment is comprised of multiple, aggregated operating
segments.  Please tell us the operating segments that are aggregated into the PCB reportable
segment and explain how you applied the guidance in ASC 280 -10-50-11(a) to (e) when
determining that these various operating segments qualified for aggregation into one reportable
segment.  If there are any differences in your operating segments, tell us why you determined
that disaggregation was not warranted.

Form 8 -K furnished August 2, 2017

Business Outlook

4. Please revise to include a quantitative reconciliation of your non -GAAP guidance m easures to
the most directly comparable GAAP measure, or include a statement that such reconciliation is
not practicable without unreasonable effort.  Refer to guidance in Item 10(e)(1)(i)(B) of
Regulation S -K and Question 102.10 of the Non -GAAP Compliance  Disclosure and
Interpretations issued May 17, 2016.

We remind you that the company and its management are responsible for the accuracy and
adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by
the staff.

You may contact  Brittany Ebbertt, Staff Accountant at (202) 551 -3572 , or me at (202) 551 -
3449 with any questions.

Sincerely,

 /s/  Kathleen Collins

Kathleen Collins
Accounting Branch Chief
Office of Information Technologies and
Services

cc: Tony Sanchez, Corporate Controller

October 7, 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 comple ted our review of your filings .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing s 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.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain tha t the filing s include the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Patrick Gilmore

Patrick Gilmore
Accounting Branch Chief

CORRESP
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Correspondence

 September 26, 2013

VIA EDGAR SYSTEM

Mr. Patrick Gilmore, Accounting Branch Chief

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

 Washington DC,
20549

 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. Gilmore:

TTM Technologies, Inc., a Delaware corporation (referred to as the “Company”, “we”, “our” or “us”),
hereby submits its responses to the comments received from you on behalf of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) in your letter dated September 6, 2013 (the “Comment
Letter”). The individual responses of the Company to each of such comments are set forth below. The headings and numbers of our responses coincide with the headings and comment numbers set forth in the Comment Letter.

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

General

 1.
Comment: 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 menu 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 subject 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 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 equipment 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 with the governments of those countries or entities controlled by those governments.

 Securities and Exchange Commission

September 26, 2013

  Page
 2

 Company Response: The Company has no known past, current, or
anticipated contacts with Syria, Sudan, or Cuba, whether through subsidiaries, resellers, customers, distributors or other direct or indirect arrangements. The Company has provided no services or products to Syria, Sudan, or Cuba, directly or
through any of its affiliates. The Company does not maintain any assets, offices, employees, agents or affiliates in Syria, Sudan, or Cuba, and none are anticipated. The Company does not sell products or services through distributors or resellers.
As noted in your comment letter, the Company’s website includes drop down menus for requesting certain information and quotes. Please note that when such website functions were developed, the developers used a generic, expansive list of
countries to populate such drop down menus. As stated above, we have provided no services or products to Syria, Sudan, or Cuba, and we are not aware of any request for information or quotes made through our website related to Syria, Sudan, or Cuba.
Please note that we have since removed the above referenced countries, as well as Iran, from the drop down menus on our website.

With respect to Huawei and Ericsson, the products we sell to such customers are typically incorporated into larger
telecommunications and data communications systems that are used by telecom providers and large enterprises. While we generally do not have insight into the ultimate destination of our products sold to these customers, we confirm that we have not,
to our knowledge, ever provided to Huawei, Ericsson or any other customer any product customized for use in an end product exported to any party in Syria, Sudan or Cuba or any service with respect to any such product. In connection with our
responses to your Comment Letter, the Company conducted internal inquiries relating to our products sold to customers, including Huawei and Ericsson. Such inquiries did not uncover any evidence that the Company’s products have been exported to
Syria, Sudan, or Cuba.

 2. Comment: 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 three 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 company’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 sponsors 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.

 Company Response: As discussed in our response to
Comment #1 above, we have no known past, current or anticipated contacts with, and we have no assets in, Syria, Sudan or Cuba. We have made no sales in, have shipped no products to, and have had no liabilities associated with Syria, Sudan or Cuba
during the last three fiscal years and the subsequent interim period. To our knowledge, we have not provided any customer, including Huawei and Ericsson, any service or product for use in any end product destined for any party in Syria, Sudan or
Cuba. As a result, we do not believe that there exists a material investment risk for our security holders and we do not anticipate any potential impact therefrom on our company reputation or share value.

We highly value the views of our security holders and seek to actively engage them. Based on the facts that (i) we have
had no known past, current or anticipated contacts with Syria, Sudan or Cuba, (ii) the Company has not received any inquiries from investors or analysts expressing concerns regarding our business with Huawei or Ericsson, and (iii) the
Company is not aware of any proposed divestment initiatives related thereto, we do not believe that divestment initiatives have had or will have a material impact on the Company.

 Securities and Exchange Commission

September 26, 2013

  Page
 3

 3. Comment: Please address the potential for
reputational 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 note from 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.

 Company Response: As discussed in our response to
Comment #1 and Comment #2 above, the Company sells products to Huawei and Ericsson that are typically incorporated into larger telecommunications and data communications systems that are used by telecom providers and large enterprises. To our
knowledge, the Company has not provided any service or customized product to any customer, including Huawei and Ericsson, for use in any end product destined for any party in Iran, Syria, Sudan or Cuba.

At the time Huawei and Ericsson became customers of the Company, the Company did not have, and the Company does not presently
have, knowledge with respect to Huawei’s and Ericsson’s business activities in Iran, Syria, Sudan or Cuba (other than as reported in the press and in the public filings noted in your Comment Letter). We note that Huawei announced that it
will voluntarily restrict its business development activities in Iran by no longer seeking new customers and limiting its business activities with existing customers. We also note that, according to a recent press report, Ericsson has stated that it
has reduced its involvement with Iran, that it will not sign any new contract with Iranian telecommunications groups, and that at the end of 2013, Ericsson will no longer have any ongoing commitments for delivering new equipment in Iran. We also
understand from publicly available information that Ericsson’s subsidiary in Panama voluntary disclosed violations of restrictions on exports to Cuba and that since such time Ericsson has taken corrective action and changed its procedures.

Since publicly disclosing that Huawei and Ericsson are customers of the Company, the Company has not received any inquiries
from investors or analysts expressing concern regarding such business relationships. Although the Company understands that certain investors, customers and regulatory bodies have concerns about contractual relationships with companies that have
business dealings with U.S.-designated state sponsors of terrorism, based upon the foregoing, the Company does not believe that its business transactions with Huawei and Ericsson are likely to cause reputational harm to the Company. The Company
acknowledges that investor awareness in the United States and elsewhere regarding relationships with companies doing business with U.S.-designated state sponsors of terrorism has been heightened in recent years, and the Company will continue to
monitor the potential effect of investor sentiment in relation to the business we conduct with our customers, including Huawei and Ericsson.

4. Comment: 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.

 Securities and Exchange Commission

September 26, 2013

  Page
 4

 Company Response: As discussed in our response to Comment #1, Comment
#2 and Comment #3 above, we have no known past, current or anticipated contacts with Syria, Sudan or Cuba. Accordingly, we are not aware of any past, current or anticipated contacts or sales with Syria, Sudan or Cuba that involve dual use products,
components or technologies included on the Department of Commerce’s Commerce Control List.

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

 Consolidated Condensed Statements of Operations, page 3

5. Comment: 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 discontinued 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.

 Company Response: The Company considered whether we should account for the sale of SYE as a
discontinued operation pursuant to ASC 205-20-45 and concluded that the relevant criteria were not met. In conjunction with this assessment, we determined that SYE met the definition of a component in accordance with ASC 205-20-20, as it comprised
operations and cash flows that could be clearly distinguished, both operationally and for financial reporting purposes. However, given that the operations and cash flows of SYE have not been (and will not be) eliminated from the ongoing operations
of the Company as a result of the disposal transaction, we have determined that the first condition of ASC 205-20-45-1 was not met.

Prior to the disposal transaction, the Company’s international footprint included seven printed circuit board (PCB)
fabrication plants in Hong Kong, Dongguan, Guangzhou, Shanghai and Suzhou, China. SYE consisted of one of these PCB fabrication plants and a trading company, which processed external sales of PCBs manufactured not only by SYE but also by the
Company’s other fabrication plants. Subsequent to the sale of SYE, the Company has continued to manufacture PCBs in China as a core part of the ongoing operations of the Company. Additionally, the Company has established a new trading company
in China, which is expected to process approximately half of the sales to external customers that had previously been processed by SYE. For a transition period of six months, the majority of TTM’s external customer orders previously
manufactured at SYE will continue to be manufactured at that facility on behalf of TTM. The PCBs manufactured by the Company’s other fabrication plants continue to be manufactured at those facilities, and are expected to be converted to direct
orders within the next six months.

 We followed the four-step process outlined in ASC 205-20-55-3 in determining whether
the conditions of ASC 205-20-45-1 have been met:

 Step 1: Are continuing cash flows expected to be generated by the
ongoing entity?

 Step 2: Do the continuing cash flows result from a migration or continuation of activities?

Step 3: Are the continuing cash flows significant?

 Securities and Exchange Commission

September 26, 2013

  Page
 5

 The question is whether, in substance, the cash inflows of the component have
been continued after the disposal transaction. As described above, we expect a migration of revenues from the disposed component (SYE) to our ongoing operations (i.e., continued transactions with the major customers of the disposed component).

We evaluated the significance of the continuing cash flows based on a comparison between the cash flows expected to be
received by the ongoing entity divided by the cash inflows of the disposed component on a gross basis for a period of one year after the disposal. We concluded that the continuing cash flows are significant, as they represent approximately half of
the cash flows generated by SYE prior to the disposal transaction.

 Because the continuing cash flows are significant,
consideration of Step 4 was not necessary.

 As a result, we have determined that the sale of SYE did not meet the
definition of a discontinued operation pursuant to ASC 205-20-45.

 * * * * * * * * *

The Company acknowledges that:

•

 the Company is responsible for the adequacy and accuracy of the disclosure in the Company’s filings;

•

 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the
Company’s filings; 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.

 Please do not hesitate to call me at (714) 327-3000 if you have any
questions or would like any addit

CORRESP
1
filename1.htm

CORRESP

 September 13, 2013

VIA EDGAR SYSTEM

 Mr. Patrick Gilmore,
Accounting Branch Chief

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, NE

Washington DC, 20549

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. Gilmore:

The purpose of this letter is to confirm that, based on our counsel’s phone conversation with Christine Davis of your office on September 12, 2013,
we will provide our response to the Securities and Exchange Commission’s letter dated September 6, 2013 on or before October 4, 2013.

Sincerely,

  /s/ Todd B. Schull

Todd B. Schull,

Executive Vice President,

Chief Financial Officer,

Secretary and Treasurer

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

August 30, 2012

Via E -mail
Steven W. Richards
Executive Vice President , CFO and Secretary
TTM Technologies , Inc.
1665 Scenic Avenue, Suite 250
Costa Mesa , California 92 626

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 completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or 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
feder al securities laws of the United States.  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 ru les require.

Sincerely,

 /s/ Patrick Gilmore

Patrick Gilmore
Accounting Branch Chief

CORRESP
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Response Letter

 August 1, 2012

 VIA EDGAR SYSTEM

 Mr. Patrick Gilmore, Accounting Branch Chief

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

Washington DC, 20549

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. Gilmore:

 TTM
Technologies, Inc., a Delaware corporation (referred to as the “Company”, “we”, “our” or “us”), hereby submits its responses to the comments received from you on behalf of the Division of Corporation Finance
of the Securities and Exchange Commission (the “Commission”) in your letter dated July 19, 2012 (the “Comment Letter”). The individual responses of the Company to each of such comments are set forth below. The headings and
numbers of our responses coincide with the headings and comment numbers set forth in the Comment Letter.

 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 Policies and Estimates

 Long-Lived
Assets, page 38

1.            Comment: We note that
during the year ended December 31, 2011, goodwill allocated to the North America segment was impaired. In future filings, to the extent you perform two-step impairment tests after performing qualitative analyses, and any of your reporting units
with goodwill are at risk of failing “step one” of ASC 350-20-35-4 because the fair value is not substantially in excess of the carrying value, please disclose the following information:

•

 The percentage by which 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;

 Securities and Exchange
Commission

 August 1, 2012

 Page 2

•

 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 at risk we encourage you to
disclose that fact.

 Company Response: As requested, in future filings, in the event we perform two-step
impairment tests after performing qualitative analyses, and any of our reporting units with goodwill are at risk of failing “step one” of ASC 350-20-35-4 because the fair value is not substantially in excess of the carrying value, we will
expand our disclosure to include the additional requested information. In addition, in future filings, if we view our reporting units as not at risk after performing such impairment tests, we will disclose such fact.

Liquidity and Capital Resources, page 44

 2.            Comment: 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 cash 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.

 Company
Response: As of December 31, 2011, we had an aggregate of approximately $71.7 million of cash and cash equivalents held by our foreign subsidiaries, approximately $70.4 million of which was held in Asia, and approximately $1.3 million of
which was held in Europe. As requested, we will expand our disclosure in future filings to include the total amount of cash and cash equivalents held by our foreign subsidiaries.

As of December 31, 2011, approximately $7.6 million of the cash and cash equivalents held by our foreign subsidiaries was
located in our Shanghai backplane assembly plant, which is included in our North America operating segment. On page 45 and 71 of our Annual Report on Form 10-K for the fiscal year ended December 31, 2011 (“10-K”), we disclosed that
cash and cash equivalents located in the Shanghai backplane assembly plant are expected to be repatriated, and on page 71 and 87 of the 10-K, we disclosed that we recorded U.S. income taxes on earnings attributable to the Shanghai backplane assembly
plant.

 Based upon our analysis of the liquidity of the Company, including our foreign operations, we concluded that
significant capital was needed in our Asia Pacific operating segment to fund current operations and capital expenditures and to service indebtedness located in Asia. As a result, we concluded and disclosed on page 71 of the 10-K that we do not
intend to repatriate earnings from our foreign subsidiaries within our Asia Pacific operating segment and consider such earnings as permanently reinvested. As of December 31, 2011, approximately $62.8 million of cash and cash equivalents was
held by our foreign subsidiaries within the Asia Pacific operating segment. Assuming we were to repatriate earnings from our Asia Pacific operating segment, we concluded that the determination of the income tax consequences of repatriating such
earnings is not practicable because there are various methods available to us to repatriate such earnings, each with different tax

 Securities and Exchange
Commission

 August 1, 2012

 Page 3

consequences. In addition, if such earnings were to be repatriated, we expect foreign tax credits to be available to offset the potential tax liability; however, the timing and amount of such
foreign tax credits is uncertain. The calculation of the available foreign tax credit is dependent upon the uncertain timing of the repatriation and projections of significant future uncertain events. As we do not currently intend to repatriate
earnings from our Asia Pacific operating segment, we determined that making forecasts related to such an event is not practicable. Accordingly, on page 87 of the 10-K, we stated that the “determination of the unrecognized deferred tax liability
for the temporary difference related to these undistributed earnings is not practicable.”

 Notes to Consolidated Financial Statements

 Note (2) Summary of Significant Accounting Policies

 Revenue Recognition, page 70

3.            Comment: We note
from disclosure in the business section that you provide certain value-added services as well as design and engineering services. 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 allocate arrangement consideration and how you recognize revenue for the services.

Company Response: We provide value-added design and engineering services, which are customer specific R&D-type projects
or customer outsourcing of design activity. These design and engineering services represent a niche area of revenue for us. For these services, we recognize revenue at completion of the project, which occurs when the customer approves and receives
delivery of the design. At that point, ownership of the design vests in the customer. While in some cases we may ultimately manufacture the printed circuit board (PCB) products that are designed by us in connection with such services, the customer
is free to submit the design to any PCB manufacturer of its choosing for fabrication. To the extent we are ultimately selected to manufacture such PCB products, the terms and conditions of the arrangement are subject to separate negotiation at the
time the customer makes such determination. In 2010 and 2011, these services generated revenue of approximately $0.4 million and $0.5 million, respectively, or 0.03% of net sales in each such year.

Note (14) Commitments and Contingencies, page 96

 4.            Comment: We note your disclosure indicating that “the amount of any reasonably possible or probable loss for known matters
would not be material to the Company’s financial condition.” Please tell us what consideration was given to disclosing whether such matters may be material to your results of operations and cash flows or alternatively, your financial
statements as a whole. In this regard, 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).

Company Response: We review the status, and carefully consider the potential materiality and outcome, of all known legal
matters on a quarterly basis in order to maintain compliance with the requirements of ASC Topic 450 and Item 103 of Regulation S-K. In many cases, we are unable to estimate reasonably possible or probable losses due to the preliminary nature of
the legal matters, the indeterminate amount of damages being sought, the need to resolve significant issues of fact, and/or the presence of novel issues of law. Notwithstanding the difficulty in estimating such reasonably possible or probable
losses, based upon our knowledge as of the date of the 10-K, as well as a review

 Securities and Exchange
Commission

 August 1, 2012

 Page 4

of amounts of claimed damages in certain matters and our consideration of the advice we received from our professional advisors (including legal counsel), we believed that any potential
liabilities arising from known legal matters would not have a material adverse effect on our financial condition, results of operations, or cash flows. However, given the uncertainty of the outcomes of the known legal matters, we also disclosed on
page 96 of the 10-K that “the ultimate potential loss could have a material adverse effect on the Company’s financial condition or result of operations in a particular period.” In future filings, we will expand our disclosure
regarding known legal matters to include the expected impact to all of our consolidated financial statements.

 * * * * * * * * *

 The Company acknowledges that:

•

 the Company is responsible for the adequacy and accuracy of the disclosure in the filings;

•

 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; 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.

 Please do not hesitate to call me at (714) 327-3000 if you have any questions or
would like any additional information.

 Very truly yours,

 /s/ Steven W. Richards

 Steven W. Richards

 EVP, Chief Financial Officer,

 Treasurer and Secretary

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

November 30, 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 completed our review of your Form 8-K and related filings and have no further
comments at this time on the specific issues raised.
Sincerely,

Jaime G. John Staff Accountant

CORRESP
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Correspondence

TTM Technologies, Inc.

2630 South
Harbor Boulevard

Santa Ana, California 92704

November 29, 2010

VIA 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: Jaime John

  Re:

TTM Technologies, Inc. (the
“Company”)

Form 8-K
Filed November 17, 2010

File No. 000-31285

Dear Ms. John:

Reference is made to the letter from the staff (the
“Staff”) of the Securities and Exchange Commission (the
“Commission”) dated November 18, 2010 providing comments to
the Company’s filing referenced above. The Company respectfully advises
the Staff that it has filed today an amended Form 8-K stating that the
Company determined to dismiss KMPG LLP, and has included in the
Form 8-K/A an Exhibit 16 letter from KMPG LLP referencing the
Form 8-K/A. In connection with the filing of the Form 8-K/A, the
Company acknowledges that:

  •

it 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

  •

it 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.

If you have any questions regarding this filing, please do not
hesitate to contact me at (714) 327-3072.

Sincerely,

/s/ Steven W.
Richards

Steven W. Richards,

Executive Vice President and

Chief
Financial Officer

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

September 9, 2010
Steven W. Richards Executive Vice President and CFO TTM Technologies, Inc.  2630 South Harbor Boulevard Santa Anna, CA 92704
Re: TTM Technologies, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2009
File No. 000-31285

Dear Mr. Richards:
We have completed our review of your Form 10-K and related filings and have no further
comments at this time on the specific issues raised.
Sincerely,

Patrick Gilmore Accounting Branch Chief

 [Officer’s Name] [Company Name]  [Date] Page 2

CORRESP
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Correspondence

September 8, 2010

VIA 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. (the “Company”)

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:

Reference is made to the letter from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) dated July 23, 2010 to Kenton K. Alder, Chief Executive Officer of the Company, providing comments
to the Company’s filings referenced above. In connection with the Company’s response to the Staff’s comments by
letter dated August 12, 2010, the Company acknowledges that:

    •

    it is responsible for the adequacy and accuracy of the disclosure in the filings;

    •

    Staff comments or changes to disclosure in response to Staff comments do not foreclose the
Commission from taking any action with respect to the filings; and

    •

    it 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.

If you have any questions regarding this filing, please do not hesitate to contact me at (714) 327-3072.

Sincerely,

/s/ Steven W. Richards

Steven W. Richards,

Executive Vice President and

Chief Financial Officer

CORRESP
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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

CORRESP
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Correspondence

Brandon F. Lombardi

Tel 602.445.8335

Fax 602.445.8679

LombardiB@gtlaw.com

VIA EDGAR

August 3, 2010

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:

I am writing on behalf of our client, TTM Technologies, Inc. (the “Company”), in regards to
the letter dated July 23, 2010 provided by the staff of the Securities and Exchange Commission to
Kenton K. Alder, Chief Executive Officer of the Company.

As we discussed on our telephone call today, the Company is in the process of finalizing its
Current Report on Form 10-Q for the quarter ended June 30, 2010 and related second quarter earnings
release, and is preparing for an upcoming board of directors meeting in China to be held in August.
As a result, per our discussion, the Company will file a response to the letter no later than
August 20, 2010.

    Very truly yours,

    /s/  Brandon Lombardi

    Brandon Lombardi

    For the Firm

    cc:

    Steven Richards

Bruce Macdonough

July 23, 2010
 Kenton K. Alder President and CEO TTM Technologies, Inc.
2630 South Harbor Boulevard
Santa Anna, CA 92704
Re: TTM Technologies, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 20009
Filed March 15, 2010 Form 8-K/A Filed April 26, 2010 File No. 000-31285

Dear Mr. Alder:
We have reviewed your filings 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 ten 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.
 Form 10-K for the Fiscal Year Ended December 31, 2009

 Item 1.  Business

 Customers and Markets, page 7

 1. 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. gove rnment in your customer discussion.
Please also explain why you have not pr ovided the disclosure required by Item
101(c)(1)(ix) of Regulation S-K.

 Kenton K. Alder TTM Technologies, Inc. July 23, 2010 Page 2   Suppliers, page 9

 2. We note your disclosure in th is section that “most of our  raw materials are generally
available in the open market from numerous  other potential supplie rs.”  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 issu e to our letter dated
May 30, 2008, in which we raised comment s 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 s ources of supply in your backplane assembly
business segment.
 Backlog, page 9

 3. During your May 6, 2010 earnings call, you disclo sed a book to bill ratio for printed
circuit boards.  However, in your Business se ction, 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 in dication 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.

Item 1A.  Risk Factors

 Our results of operations are often subject to  demand fluctuations and seasonality… page 20

 4. You indicate that you have “experienced sales fluc tuations due to seasonal patterns in the
capital budgeting and purchasing cycle, as we ll 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 busin ess 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.

Item 2.  Properties, page 32

 5. 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 In struction 1 to Item 102 of Regulation S-K.

 Kenton K. Alder TTM Technologies, Inc. July 23, 2010 Page 3  Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations
 Overview, page 37

 6. 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 financ ial 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 im pact 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.
 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. We note in your disclosure here and in your schedule of valuation and qualifying
accounts on page 92 that you record inventory re serves 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 th at 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 ba sis for your inventory and why you believe
including this reserve as a valuation and qualifying account is appropriate.
 Item 10.  Directors, Executive Officers of the Registrant and Corporat e Governance Matters
(Incorporated by Reference from Definitive Pr oxy Statement on Schedule 14A, filed April 12,
2010)
 Committees of the Board of Directors, page 8

 8. Please advise what consideration you gave to  the requirements of It em 407(c)(2)(vi) of
Regulation S-K.  You indicate that your nom inating and corporate governance committee
considers diversity when recommending dir ector nominees for election and that the
committee “evaluates its effectiveness in achie ving diversity on the board of directors

 Kenton K. Alder TTM Technologies, Inc. July 23, 2010 Page 4
through its annual review of board member  composition, which identifies ethnicity,
gender, and industry experience.”  In future f ilings, we would expect to see more detailed
disclosure with respect to how your no minating and corporate governance committee
considers diversity in identif ying 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 descript ion of how this policy is implemented, as
well as how the nominating and corporate governance committee assesses the effectiveness of its policy.
 Item 11. Executive Compensation (Incorporated by Reference from Definitive Proxy Statement
on Schedule 14A, filed April 12, 2010), page 30
 9. Item 402 of Regulation S-K requires that you provide compensation information for your
principal executive officer (PEO ), principal financial officer  (PFO), and three of your
most highly compensated executive officers ot her than your PEO and PFO.  We note that
you provide compensation information for f our executive officers, including your PEO
and PFO, rather than five officers as contem plated by Item 402(a) of Regulation S-K.
Please advise.

Form 8-K/A filed April 26, 2010

 Exhibit 99.1

 Notes to the Financial Statements

 34 Reconciliation to US GAAP, page 73

 10. Please tell us how you considered the guidance of Item 17(C)(2)(iii) of Form 20-F.  In
this regard, it does not appear that you have presented a stat ement of cash flows prepared
in accordance with generally accepted accounting principles in the United States or with
International Accounting Standard No. 7 or alternatively, furnishing in a note to the
financial statements a quantif ied description of the materi al differences between cash
flows reported in accordance with Hong Kong Financial Reporting Standards and cash flows that would be reported in a statemen t of cash flows prepared in accordance with
accounting principles generally a ccepted in the United States.

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.

 Kenton K. Alder TTM Technologies, Inc. July 23, 2010 Page 5
 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 David Edgar, Staff Accountant, at (202) 551-3459 or Patrick Gilmore,
Accounting Branch Chief, at (202) 551-3406 if you have questions regarding comments on the
financial statements and related matters.  Plea se contact Courtney Haseley, Staff Attorney, at
(202) 551-3548 or me at (202) 551- 3735 with any other questions.

Sincerely,

Barbara C. Jacobs Assistant Director

Mail Stop 4561          July 29, 2008      Mr. Kenton K. Alder     President and Chief Executive Officer  TTM Technologies, Inc.   2630 South Harbor Boulevard Santa Ana, CA 92704
Re: TTM Technologies, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2007
Filed March 17, 2008
File No. 0-31285

Dear Mr. Alder:

 We have completed our review of your Form 10-K and related filings and have
no further comments at this time on the specific issues raised.

Sincerely,
         Mark Kronforst
Accounting Branch Chief

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GREENBERG TRAURIG, LLP

Michael L. Kaplan

Tel. 602.445.8313

Fax 602.445.8615

KaplanM@gtlaw.com

July 15, 2008

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

Attention: Filing Desk

    Re:

    TTM TECHNOLOGIES, INC.

Form 10-K for the Fiscal Year Ended December 31, 2007 Filed March 17, 2008

Definitive Proxy Statement Filed April 3, 2008

Form 10-Q for the Quarterly Period Ended March 31, 2008 Filed May 7, 2008

File No. 0-31285

Ladies and Gentlemen:

     On behalf of our client, TTM Technologies, Inc., a Delaware corporation (the “Company”), we
are responding to the Staff’s comments set forth in the letter dated May 30, 2008 (the “Comment
Letter”) to Kenton K. Alder, Chief Executive Officer of the Company. The individual responses of
the Company to each of the Staff’s comments are set forth below. The headings and numbers of the
responses coincide with the headings and comment numbers set forth in the Comment Letter. In this
letter, references to “we,” “our” and “us” refer to the Company.

Form 10-K for the Fiscal Year Ended December 31, 2007

Item 1. Business

Suppliers, page 8

     1. Our PCB Manufacturing business segment uses raw materials that are commodities (laminate,
copper foil, chemicals, etc.) to fabricate printed circuit boards. These raw materials are
generally readily available at our choice from numerous vendors. On the other hand, our Backplane
Assembly business segment generally uses manufactured components (printed circuit boards,
connectors, capacitors, resistors, diodes, etc.) that we assemble into finished products. In some
instances our customers will require us to use a specific component(s) from a particular
supplier(s) or require us to use a component provided by the customer itself, in which case we will
have a single or limited number of suppliers for these specific components. If we do not receive
these limited or sole- sourced components on a timely basis, we may not be able to complete the
assemblies on a timely basis, which would delay our ability to ship the finished products and our
ability to recognize revenue. In instances when there is an interruption or delay in the supply of
these components, we generally try to work with our customers to identify acceptable alternative
components and suppliers from which to order. For example, if the customer specifies that we use
an AMD chip, and we are unable to obtain that AMD chip on a timely basis, then we might ask the
customer to approve the use of an Intel chip (or other substitute that is readily available at such
time). We will clarify the disclosure of this issue in the Business section of future filings.

Securities and Exchange Commission

July 15, 2008

Page 2

Item 1A, Risk Factors

Increasingly, our larger customers are requesting that we enter into supply agreements with
them that have increasingly restrictive terms and conditions . . . page 19

     2. Entering into these supply agreements has not had a material impact on our historical
operating results. Our future operating results could be impacted by increased costs associated
with future product liability and warranty claims to the extent that our exposure for such claims
under these supply agreements is greater than our exposure under our standard terms and conditions.
In addition, to the extent that we agree to provide extended payment terms, our working capital
and operating results may be adversely impacted. We have not disclosed trends or uncertainties
associated with these supply agreements in MD&A because we do not believe they are material.
However, because it’s possible that these trends could become material in the future, we have
included them as a risk factor. If they do become material, we will discuss these trends as part
of MD&A in future filings.

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

Critical Accounting Policies and Estimates

Business Combinations and Asset Retirement Obligation and Environmental Liabilities.

     3. In connection with our prior business acquisitions, we have engaged outside valuation firms
to provide us with an appraisal report to assist us in our determination of purchase price
allocation. However, our management is responsible for making the final purchase price allocation.
We review the data from the appraisal reports and may make adjustments as we deem appropriate as
part of our process for allocating purchase price. The outside valuation firms do not review our
final determination of purchase price allocation. The same would hold true for environmental
consultants that may assist us in evaluating environmental liabilities. Therefore, we respectfully
submit that the consent of these outside independent valuation firms and/or environmental
consultants as experts is not required by Rule 436(b). However, in consideration of the Staff’s
comments, we will omit references to the use of appraisal reports from outside valuation firms
and/or environmental consultants in future filings.

Item 9A, Controls and Procedures, page 40.

     4. In response to the Staff’s comment, we confirm that our disclosure controls and procedures
for the periods covered by our Form 10-K for the year ended December 31, 2007 and Form 10-Q for the
quarterly period ended March 31, 2008 met all of the requirements of Rule 13a-15(e). In future
filings, we will expressly tie our effectiveness conclusion to the disclosure controls and
procedures set out in Rule 13a-15(e).

Definitive Proxy Statement

Certain Relationships and Related Transactions, page 33

     5. Our policies and procedures for reviewing, approving or ratifying related party
transactions are disclosed in our Audit Committee Charter and our Corporate Governance Guidelines,
which are referenced on page 5. However, in response to the Staff’s comment, we will include a
description of such policies in future filings.

Securities and Exchange Commission

July 15, 2008

Page 3

Form 10-Q for the Quarterly Period Ended March 31, 2008

Notes to Consolidated Condensed Financial Statements

Note (13) Metal Reclamation, page 14

     6. On March 21, 2008, we received a $3.7 million settlement payment from a vendor for
accumulated underpayment for gold reclamation at our Redmond, Washington, facility. We use gold
baths to plate some of the printed circuit boards we manufacture, and we hire third-party vendors
to reclaim the excess gold. During the first quarter of 2008, in response to the rising price of
gold as well as other factors, we performed an analysis to determine why net gold costs at our
Redmond facility were substantially higher than at our other facilities. Our investigation led us
to suspect there were historical weighing errors by a specific vendor resulting in underpayments.
We approached the vendor with our concerns on or around February 28, 2008, and after some
negotiations, the vendor rectified the situation by agreeing to pay a $3.7 million settlement
payment relating to the issue. The settlement payment covered the period from fiscal 1999 to
2007.The impact on each previous reporting period was insignificant.

We accounted for this settlement similar to a gain contingency. Although the underpayment relates
to prior years, the discrepancy was discovered and negotiated in the first quarter of 2008. The
settlement was a product of negotiations and estimations and does not necessarily represent actual
reimbursement. We recognized the recovery in the first quarter of 2008 when it was realized. No
disclosure was made in our 10-K for the year ending December 31, 2007, because the contingency was
not then known. We reported the recovery as a separate component of income from continuing
operations and disclosed the nature and financial effects of the transaction in the notes to the
financial statements. In addition, we highlighted this recovery in our earnings call and press
release as being a temporary adjustment to operating income.

     The Company acknowledges that:

    •

    the Company is responsible for the adequacy and accuracy of the disclosure in
the filings;

    •

    staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; 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.

     Please call the undersigned with any questions or comments you may have regarding the
Company’s responses to the Staff’s comments. In addition, please send all written correspondence
directly to the undersigned.

    Very truly yours,

    /s/ Michael L. Kaplan

    Michael L. Kaplan

Securities and Exchange Commission

July 15, 2008

Page 4

Enclosures

MLK:bmc

cc: Kenton K. Alder

Mail Stop 4561         February 15, 2008  Mr. Kenton K. Adler Chief Executive Office TTM Technologies, Inc. 2630 South Harbor Boulevard Santa Ana, CA 92704
Re: TTM Technologies, Inc.
  Registration Statement on Form S-3
Filed January 15, 2008
  File No. 333-148687

Dear Mr. Adler:

We have limited our review of your filing to those issues we have addressed in
our comments.  Where indicated, we think you should revise your document in response
to these comments.  If you disagree, we w ill consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  In some of our comme nts, we may ask you to provide us with
information so we may better understand your  disclosure.  After reviewing this
information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Registration Statement on Form S-3

Exhibits
1. Please tell us whether you plan to file th e form of indenture relating to the debt
securities in a pre-effect ive amendment.  Refer to Sections 305(b)(2) and
309(a)(1) of the Trust Indent ure Act of 1939.  Please note that an indenture must
be filed and qualified prior to effectivene ss of the registration statement where the
debt securities are being offered on a dela yed basis and the specific terms of that
debt have yet to be determined.  Please refer to interpretati on D.31 of the July
1997 manual of publicly available tele phone interpretations, which provides
guidance applicable  to your filing.

Mr. Kenton K. Adler
February 15, 2008
TTM Technologies, Inc. Page 2  2. Although the Form T-1 may be f iled as an exhibit at the time of a take down off
the shelf, please revise to list the Form T-1 as Exhibit 25 and indicate that you will file it by amendment.
3. Please submit a revised legal opinion that  includes a signatory .  Also, please
confirm that the reference to the Delaware General Corporation Law is intended to encompass other Delaware statutory provisions as well as all applicable
provisions of the Delaware Constitution and reported ju dicial decisions
interpreting these laws.

Form 10-Q for the Quarterly Period Ending October 1, 2007

Controls and Procedures, page 28
4. In expressing your conclusions regardi ng the effectiveness of your “disclosure
controls and procedures”, you recite only a portion of that term as defined in Rule
13a-15(e).  In your response letter, please indicate whethe r the evaluation of
effectiveness was conducted with respect to  the complete definition, rather than
only the portion of the definition  that you recite in this se ction.  In future filings,
please tie the effectiveness conclusion to th e definition of disclosure controls and
procedures set out in Rule 13a-15(e) , or recite the entire definition.

*****

As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cove r letter with your amendment that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendmen t and responses to our comments.
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 all in formation required under
the Securities Act of 1933 and that they have  provided all information investors require
for an informed investment decision.  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.
Notwithstanding our comments, in the even t the company requests acceleration of
the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that:

Mr. Kenton K. Adler
February 15, 2008 TTM Technologies, Inc. Page 3  ‚ should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose th e Commission from taking any action with
respect to the filing;
 ‚ the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective,  does not relieve the company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and
 ‚ the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
  In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.
We will consider a written request for acceleration of the effective date of the
registration statement as conf irmation of the fact that t hose requesting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te to the proposed public offering of the
securities specified in the above registration statement.  We will act  on the request and,
pursuant to delegated authority, grant acce leration of the effective date.
We direct your attention to Rule 461  regarding requesting acceleration of a
registration statement.  Please allow adequate  time after the filing of any amendment for
further review before submitting a request for acceleration.  Please provide this request at
least two business days in advance of the requested effective date.
 If you have any questions, please call LaTonya Reynolds at (202) 551-3535.
Should you require further assistance, you may contact me at (202) 551-3462.             S i n c e r e l y ,             M a r k  P .  S h u m a n          B r a n c h  C h i e f  -  L e g a l

 cc:  Via Facsimile: (602) 445-8615

Michael L. Kaplan, Esq. Greenberg Traurig, LLP

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TTM Technologies, Inc.

2630 South Harbor Blvd.

Santa Ana, CA 92704

July 1, 2008

Mark Kronforst

Accounting Branch Chief

Division of Corporation Finance

U.S. Securities and Exchange Commission

Mail Stop 4561

Washington, D.C. 20549

     Re: TTM Technologies, Inc; File No. 0-31285

Dear Mr. Kronforst:

     Following up on a conversation with Marc Thomas, Staff Accountant, we hereby request an
extension of time to deliver our response to the Staff’s May 30, 2008 comment letter until July 15,
2008.

     Thank you for your consideration of this request.

    Sincerely,

    /s/ Steve Richards

    Steve Richards

    Chief Financial Officer

Mail Stop 4561

        May 30, 2008

Mr. Kenton K. Alder
President and Chief Executive Officer
TTM Technologies, Inc.
2630 South Harbor Boulevard
Santa Ana, CA 92704

Re: TTM Technologies, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2007
Filed March 17, 2008
 Definitive Proxy Statement
Filed April 3, 2008
Form 10-Q for the Quarterly Period Ended March 31, 2008
Filed May 7, 2008
File No. 0-31285

Dear Mr. Alder:

We have reviewed the above-referenced f ilings and have the following comments.
If indicated, we think you s hould revise your documents in response to these comments.
If you disagree, we will consider your explanation as to why our comment is inapplicable
or a revision is unnecessary.  Please be as de tailed as necessary in your explanation.  In
some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.

Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the Fiscal Year Ended December 31, 2007

Item 1.  Business

Suppliers, page 8
1. We note your disclosure in this sectio n that “most of our raw materials are
generally readily available in the op en market from numerous potential

Mr. Kenton K. Adler
TTM Technologies, Inc.
May 30, 2008      Page 2
suppliers.”  However, this statement is in consistent with the st atement in your risk
factor on page 15 that “components for b ackplane assemblies in some cases have
sole or limited sources of supply.”  Pleas e explain this discrepancy.  In your
response letter provide us with additional information regarding the nature of the
components that are only available from sole or limited suppliers, how those components are used in your business,  and the potential impact that an
interruption in the supply of each of  these components might have on your
operations.

Item 1A. Risk Factors
Increasingly, our larger customers are request ing that we enter into supply agreements
with them that have increasingly rest rictive terms and conditions…, page 19
2. Describe to us the impact that entering  into these supply agreements has had on
your historical operating resu lts and the potential impact  on your future results.
As part of your response, tell us how you considered disclosing any material trends or uncertainties associated with these agreements in your MD&A.

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

Critical Accounting Policies and Estimates

Business Combinations and Asset Retirement Obligation and Environmental Liabilities,
pages 30-32
3. We note your references to the use of a va luation firm which provides you with an
appraisal report utilized in determini ng the purchase price allocation of your
business acquisitions.  Please note that  when you refer to an independent
valuation specialist you need to disclose the name of the expert and, if your
annual report is incorporated by referen ce into a Securities Act registration
statement, include the expert’s consent.  Refer to Rule 436(b)  of Regulation C and
confirm to us that you will comply with this guidance in your future filings.  Note that similar concerns may apply to y our use of environmental consultants.

Item 9A. Controls and Procedures, page 40
4. We note the change that you have made to the disclosure in this section (and in
the corresponding section of your Form  10-Q for the quarterly period ended
March 31, 2008) in response to our lette r dated February 15, 2008, in which we
raised comments on your Form S-3 filed on January 15, 2008 and your Form 10-Q for the quarterly period ended October 1, 2007.  However, in your conclusions regarding the effectiveness of your disclosure cont rols and procedures, you

Mr. Kenton K. Adler
TTM Technologies, Inc.
May 30, 2008      Page 3
continue to recite only a portion of the definition of disclosure controls and
procedures provided in Rule 13a-15(e).  In your response le tter, please confirm, if
true, that your disclosure controls and procedures fo r the periods covered by your
Form 10-K and the Form 10-Q for the quarterly period ended March 31, 2008 met
all of the requirements of Rule 13a-15(e).  In future filings, please expressly tie your effectiveness conclusion to disclosure controls and procedures as set out in
Rule 13a-15(e), or recite  the entire definition.

Definitive Proxy Statement

Certain Relationships and Re lated Transactions, page 33
5. It appears that you have  not provided a descript ion of your policies and
procedures for reviewing, approving or ra tifying related part y transactions, as
required by Item 404(b) of Regulation S-K.  Please advise.

Form 10-Q Filed for the Period Ended March 31, 2008
Notes to Consolidated Condensed Financial Statements
Note (13) Metal Reclamation, page 14
6. We note the recognition of $3.7 million of income, in the first quarter of 2008,
relating to pricing discrepancies that covered several year s.  Provide us with the
nature and timing of the pricing discrepa ncies and the periods impacted.  In your
response, address why it was appropriate to  record this amount as income in the
period ended March 31, 2008.

* * * * * *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please  submit all correspondence and supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  If you amend your
filing(s), you may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cover letter that keys your response to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your responses to our comments.

Mr. Kenton K. Adler
TTM Technologies, Inc.
May 30, 2008      Page 4
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 all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in writing, a
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.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

 You may contact Marc Thomas, Staff Accountant, at (202)  551-3452 if you have
any questions regarding comments on the fina ncial statements and related matters.
Please address questions rega rding all other comments to  Matthew Crispino, Staff
Attorney, at (202) 551-3456 or Mark P. Shum an, Legal Branch Chief, at (202) 551-3462.
If you need further assistance, you may contact me at (202) 551-3451.

Sincerely,

      Mark Kronforst
Accounting Branch Chief

CORRESP
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corresp

[On TTM Technologies Letterhead]

April 4, 2008

VIA FACSIMILE (202-772-9210) AND EDGAR

LaTonya D. Reynolds

Securities and Exchange Commission

450 Fifth Street, N.W.

Judiciary Plaza

Washington, D.C. 20549

    Re:

    TTM Technologies, Inc.

Registration Statement on Form S-3

File No. 333-148687

Dear Ms. Reynolds:

     In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of
1933, as amended, TTM Technologies, Inc. (the “Company”) hereby requests acceleration of the
effectiveness of the Company’s Registration Statement on Form S-3 (No. 333-148687) (as amended, the
“Registration Statement”) to 10:00 a.m. Eastern time on Monday, April 7, 2008, or a soon thereafter
as practicable.

     The Company hereby withdraws its prior request for acceleration of the effectiveness of the
Registration Statement.

     The Company acknowledges that (1) should the Commission or staff, acting pursuant to delegated
authority, declare the Registration Statement effective, it does not foreclose the Commission from
taking any action with respect to the filing; (2) the action of the Commission or the staff, acting
pursuant to delegated authority, in declaring the Registration Statement effective does not relieve
the Company from its full responsibility for the adequacy and accuracy of the disclosure in the
filing; and (3) the Company may not assert such action as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

     Upon declaration of effectiveness of the Registration Statement, please advise Michael Kaplan
of Greenberg Traurig at (602-445-8313) to confirm effectiveness or to communicate any questions or
concerns you may have regarding this letter.

     Thank you for your consideration.

    Sincerely,

    /s/ Steven W. Richards

    Steven W. Richards

Executive Vice President

and Chief Financial Officer

cc: Michael L. Kaplan, Esq.

GREENBERG TRAURIG, LLP

Michael L. Kaplan

Tel. 602.445.8313

Fax 602.445.8615

KaplanM@gtlaw.com

April 4, 2008

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

Attention: Filing Desk

    Re:

    TTM TECHNOLOGIES, INC.

Registration Statement on Form S-3

File No. 333-148687

Ladies and Gentlemen:

     On behalf of our client, TTM Technologies, Inc., a Delaware corporation (the “Company”), we
are responding to the Staff’s comments set forth in the letter dated April 3, 2008 (the “Comment
Letter”) to Kenton K. Alder, Chief Executive Officer of the Company. The individual responses of
the Company to each of the Staff’s comments are set forth below. The headings and numbers of the
responses coincide with the headings and comment numbers set forth in the Comment Letter. In this
letter, references to “we,” “our” and “us” refer to the Company.

Incorporation of Certain Information by Reference, page ii

     1.     We are pleased to inform the Staff that we filed our definitive proxy statement, which
includes the information required by Part III of Form 10-K, on April 3, 2008.

     Please call the undersigned with any questions or comments you may have regarding this letter.
In addition, please send all written correspondence directly to the undersigned.

    Very truly yours,

    /s/ Michael L. Kaplan

    Michael L. Kaplan

Enclosures

MLK:bmc

cc: Kenton K. Alder

Mail Stop 4561         A p r i l  3 ,  2 0 0 8   Mr. Kenton K. Adler Chief Executive Office TTM Technologies, Inc. 2630 South Harbor Boulevard Santa Ana, CA 92704
Re: TTM Technologies, Inc.
  Amendment No. 2 to Form S-3
Filed March 21, 2008
  File No. 333-148687

Dear Mr. Adler:

We have reviewed your response to our letter dated February 15, 2008 in
connection with the above referenced fili ng and have the following comments.  If
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Pleas e be as detailed as necessary  in your explanation.  After
reviewing this information, we may raise additional comments.
 Incorporation of Certain Info rmation by Reference, page ii

1. The incorporated Form 10-K for the year ended December 31, 2007 does not currently include the Part III informa tion, which you incorporate by reference
from a definitive proxy statement that has not  yet been filed.  Prior to the desired
effective date of the registration statemen t, the information required by Part III of
Form 10-K must be filed in an amende d Form 10-K that is incorporated by
reference into the Form S-3, or in a filed, definitive proxy statement .  See Interpretation H.6 of the July 1997 Ma nual of Publicly Available Telephone
Interpretations of the Division of Corporation Finance.

*****
  As appropriate, please amend your filing in response to these comments.  Each responsive amendment should also include a marked copy of the amended filing that conforms with the provisions of Rule 310 of Regulation S-T.  Marked copies such as
those in HTML format that show changes w ithin paragraphs help us to expedite our
review.  Please furnish a cover letter with your amendments that keys your responses to
our comments and provides any requested in formation.  Detailed cover letters greatly

Mr. Kenton K. Adler
April 3, 2008 TTM Technologies, Inc. Page 2  facilitate our review.  Please understand th at we may have additional comments after
reviewing your amendments and responses to our comments.
In view of the fact that we have furthe r comments, please confirm in writing that
you have withdrawn your prior request for acce leration of the effective date of the
registration statement.  To facilitate the proce ssing of your filing we suggest that you
submit another request for acceleration only after receiving oral assurances that we have
no further comments.
 If you have any questions, please call LaTonya Reynolds at (202) 551-3535.
Should you require further assistance, you may contact me at (202) 551-3462.             S i n c e r e l y ,             M a r k  P .  S h u m a n          B r a n c h  C h i e f  -  L e g a l

cc:  Via Facsimile: (602) 445-8615

Michael L. Kaplan, Esq.
Greenberg Traurig, LLP

Mail Stop 4561         March 19, 2008  Mr. Kenton K. Adler Chief Executive Office TTM Technologies, Inc. 2630 South Harbor Boulevard Santa Ana, CA 92704
Re: TTM Technologies, Inc.
  Amendment No. 1 to Form S-3
Filed March 13, 2008
  File No. 333-148687

Dear Mr. Adler:

We have reviewed your response to our letter dated February 15, 2008 in
connection with the above referenced fili ng and have the following comments.  If
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Pleas e be as detailed as necessary  in your explanation.  After
reviewing this information, we may raise additional comments.
 Registration Statement on Form S-3

 Legal Opinion, Exhibit 5.1

1. We note the Form of Indenture is governed  by the laws of the State of New York.
However, the legal opinion is limited to the federal laws of the United States and the laws of the states of Arizona and De laware.  In light of Section 11.10 of the
Indenture, the binding obligation conclusion is a matter of New York law, and the
law of New York may not be exclud ed from the scope of the opinion.
Additionally, the warrants are obligations of the company.  Please provide a binding obligation opinion that is applicable to the warrants.
2. We note the disclosure on pages f our through five of the legal opinion
disclaiming, among other things, any ob ligation to update or supplement the
opinion.  Please revise this disclaimer so that it is c onsistent with your obligation
to file updated legal opinions at the time of each takedown.

Mr. Kenton K. Adler
March 19, 2008 TTM Technologies, Inc. Page 2  3. We also note that the opinion contains a variety of assumptions to which we have
no objections at this time.  However, in connection with future takedowns,
updated opinions should be filed that elim inate the assumptions relating to the
future actions of the board of directors, th e specific terms of the securities, and the
like.

*****
  As appropriate, please amend your filing in response to these comments.  Each responsive amendment should also include a marked copy of the amended filing that conforms with the provisions of Rule 310 of Regulation S-T.  Marked copies such as
those in HTML format that show changes w ithin paragraphs help us to expedite our
review.  Please furnish a cover letter with your amendments that keys your responses to
our comments and provides any requested in formation.  Detailed cover letters greatly
facilitate our review.  Please understand th at we may have additional comments after
reviewing your amendments and responses to our comments.
In view of the fact that we have furthe r comments, please confirm in writing that
you have withdrawn your prior request for acce leration of the effective date of the
registration statement.  To facilitate the proce ssing of your filing we suggest that you
submit another request for acceleration only after receiving oral assurances that we have
no further comments.
 If you have any questions, please call LaTonya Reynolds at (202) 551-3535.
Should you require further assistance, you may contact me at (202) 551-3462.             S i n c e r e l y ,             M a r k  P .  S h u m a n          B r a n c h  C h i e f  -  L e g a l

 cc:  Via Facsimile: (602) 445-8615

Michael L. Kaplan, Esq. Greenberg Traurig, LLP

CORRESP
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corresp

[On TTM Technologies Letterhead]

March 13, 2008

VIA FACSIMILE (202-772-9210) AND EDGAR

LaTonya D. Reynolds

Securities and Exchange Commission

450 Fifth Street, N.W.

Judiciary Plaza

Washington, D.C. 20549

    Re:

    TTM Technologies, Inc.

    Registration Statement on Form S-3

    File No. 333-148687

Dear Ms. Reynolds:

     In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of
1933, as amended, TTM Technologies, Inc. (the “Company”) hereby requests acceleration of the
effectiveness of the Company’s Registration Statement on Form S-3 (No. 333-148687) (as amended, the
“Registration Statement”) to 10:00 a.m. Eastern time
on Monday, March 17, 2008, or as soon
thereafter as practicable.

     The Company acknowledges that (1) should the Commission or staff, acting pursuant to delegated
authority, declare the Registration Statement effective, it does not foreclose the Commission from
taking any action with respect to the filing; (2) the action of the Commission or the staff, acting
pursuant to delegated authority, in declaring the Registration Statement effective does not relieve
the Company from its full responsibility for the adequacy and accuracy of the disclosure in the
filing; and (3) the Company may not assert such action as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

     Upon declaration of effectiveness of the Registration Statement, please advise Michael Kaplan
of Greenberg Traurig at (602-445-8313) to confirm effectiveness or to communicate any questions or
concerns you may have regarding this letter.

     Thank you for your consideration.

    Sincerely,

    /s/ Steven W. Richards

    Steven W. Richards

Executive Vice President

and Chief Financial Officer

cc: Michael L. Kaplan, Esq.