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United States securities and exchange commission logo
October 19, 2023
Steven Richards
Chief Executive Officer
Shimmick Corporation
530 Technology Drive
Suite 300
Irvine, CA 92618
Re: Shimmick
Corporation
Registration
Statement on Form S-1
Filed October 5,
2023
File No. 333-274870
Dear Steven Richards:
We have reviewed your
registration statement and have the following comments.
Please respond to this letter by amending your registration
statement and providing the
requested information. If you do not believe a comment applies to your
facts and circumstances
or do not believe an amendment is appropriate, please tell us why in
your response.
After reviewing any amendment to your registration statement and
the information you
provide in response to this letter, we may have additional comments.
Registration Statement on Form S-1
Business
Our Projects, page 79
1. We note your response
to comment 1 of our letter. We note that you have provided an
example of the services
provided by one joint venture partner. Please expand your
disclosure in this
section to disclose all of the services currently being provided by joint
venture partners.
2023 Omnibus Incentive Plan, page 105
2. We note that you will
enter into the 2023 Omnibus plan. Please file this pursuant to Item
601(b)(10) of
Regulation S-K.
Steven Richards
Shimmick Corporation
October 19, 2023
Page 2
Item 16. Exhibits and Financial Statement Schedules, page II-2
3. Please file your executed Articles of Incorporation. Please see Item
601(b)(3) of
Regulation S-K.
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
Please contact Howard Efron at 202-551-3439 or Robert Telewicz at
202-551-3438 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Stacie Gorman at 202-551-3585 or Jeffrey Gabor at 202-551-2544 with any
other
questions.
Sincerely,
FirstName LastNameSteven Richards
Division of
Corporation Finance
Comapany NameShimmick Corporation
Office of Real
Estate & Construction
October 19, 2023 Page 2
cc: Zachary Davis, Esq.
FirstName LastName