United States securities and exchange commission logo





                             September 29, 2023

       Steven Richards
       Chief Executive Officer
       Shimmick Corporation
       530 Technology Drive
       Suite 300
       Irvine, CA 92618

                                                        Re: Shimmick
Corporation
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted September
15, 2023
                                                            CIK No. 0001887944

       Dear Steven Richards:

             We have reviewed your amended draft registration statement 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 by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment No. 1 to Draft Registration Statement on Form S-1

       Prospectus Summary
       Our Projects, page 6

   1.                                                   We note your response
to comment 2. Please revise your disclosure here and in the
                                                        business section to
clearly state what services are provided by you and what services you
                                                        rely upon
subcontractors and joint venture affiliates to perform.
       Our amended and restated charter documents will provide that the Court
of Chancery of the State
       of Delaware..., page 45

   2.                                                   Please revise your
disclosure here to state whether the exclusive forum applies to any
 Steven Richards
Shimmick Corporation
September 29, 2023
Page 2
      complaint asserting a cause of action arising under the Securites Act. In
this regard, we
      note your disclosure on page 115.
Management's Discussion and Analysis...
Key Factors Affecting Our Performance and Results of Operations, page 57

3.    We note your response comment 9 of our letter. We note that you included
disclosure
      regarding your backlog of contracts. Please also provide similar
disclosure regarding your
      current contracts and contracts that you have bid on.
Business
Selective Bidding Process and Project Management, page 89

4.    We note your response to comment 10. We note on page 82, you have a
project in
      Illinois. Your disclosure indicates that you have offices in California
and
      Colorado. Please expand your disclosure to clarify where you can operate
and whether
      you have sufficient equipment available at every facility, including in
those locations
      where you are bidding or whether you will be reliant on third parties.
5.    We note your response to comment 11. In your response, it appears that
you are referring
      to a success rate per contract rather than an overall success rate in
reference to your total
      bids. Please advise or revise. Please elaborate on the multi-part process
you use in
      determining whether to bid initially. Please clarify if you ever withdraw
bids once
      provided and the reasons for doing so.
Consolidated financial statements as of and for the fiscal years ended December
30, 2022 and
December 31, 2021
Note 13. Commitments and Contingencies, page F-29

6.    We note your disclosure on page 28 regarding your ongoing dispute with
AECOM.
      Please tell us what consideration you gave to including disclosure
related to this apparent
      loss contingency in the footnotes to your financial statements. Reference
is made to ASC
      Topic 450-20-50.
       You may 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
Comapany NameShimmick Corporation                            Division of
Corporation Finance
September 29, 2023 Page 2                                    Office of Real
Estate & Construction
cc:
FirstName Zachary Davis, Esq.
          LastName