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