July 24, 2006

Mr. David H. Humphrey
Branch Chief-Accountant
United States Securities and Exchange Commission
Washington, D.C.  20549-0402

Re:      Autocam Corporation
         Form 10-K for the year ended December 31, 2005 Filed March 30, 2006
         File No. 033-42670

Dear Sir:

In your letter dated July 10, 2006, you provided staff comments on the Autocam
Corporation ("Autocam" or "the Company") Form 10-K for the year ended December
31, 2005. These comments and the company responses are discussed below.

COMMENT 1:

Item 1 - Business - Environmental Matters and Government Regulation, page 12
Due to environmental and governmental regulations within your industry, it
appears that you may have conditional asset retirement obligations at some of
your locations. As such, please tell us whether there are any conditional
retirement obligations, for both your leased and owned properties, and if
material, include your accounting policy. For guidance, please refer to FIN 47
and SFAS 143.

RESPONSE: Autocam produces high precision components in modern, well maintained
facilities which in most cases are leased under operating lease agreements. The
Company is under no obligation to retire these facilities under these lease
agreements, or under any ownership arrangements. The Company has been diligent
in complying with all environmental and governmental regulations, and has no
material conditional retirement obligation under FIN 47 or SFAS 143.

COMMENT 2:

Item 7 - Management's Discussion and Analysis - Results of Operations, page 24
You present historical results of operations for the six months ended June 30,
2004 excluding any application of purchase accounting in relation to the merger
between Titan Holdings and Micron Merger Corporation. Due to the fact that the
information presented within this table is considered to be a non-GAAP measure,
please discontinue the use of the table or provide us with the substantive
support for its inclusion. For guidance refer to FR-65. In this regard, you do
not appear to discuss the impact of the basis change upon line item variances.

RESPONSE: We respectfully submit, the inclusion of this information was done to
assist the reader of our Form 10-K to more readily interpret the narrative
portion of Management's Discussion and Analysis. Although the historical results
for the six months ended June 30, 2004 (that are included in the results for
Fiscal 2004) have not been adjusted for the impact of the merger between Titan
Holdings and Micron Merger Corporation, Management's Discussion and Analysis
identifies material variances in expenses when comparing both Fiscal 2005 to
Fiscal 2004, and Fiscal 2004 to Fiscal 2003 that are a result of the merger or
were caused by the



revaluation of Autocam's balance sheet in connection with the merger.
Specifically, the following changes are discussed: Increased SG&A expenses to
complete the merger; increased interest expense, increased expense associated
with accelerated write-off of unamortized debt issue costs, goodwill impairment,
and decreased depreciation expense.

We agree that this is a non-GAAP presentation and we will exclude this type of
presentation from our future filings.

COMMENT 3:

Item 8 - Financial Statements and Supplementary Data - Note 1. Operations and
Summary of Significant Accounting Policies - Revenue Recognition, page 46.
You state on page 9 that the substantial majority of your sales are generated
under long-term, sole-source contracts with customers and that the contracts
often mandate annual price concessions of between 1% and 3%. Please tell us
whether any of these contracts contain minimum purchase guarantees and, if so,
how theses purchases are priced. Specifically, explain whether the predetermined
price concessions are recognized on a per unit basis as they occur or whether
their impact, on a per unit basis, is spread evenly over the term of the
contract.

RESPONSE: When Autocam supplies customers under long-term contracts, pricing is
determined based upon an assumption of various annual volumes and is contracted
on a per unit basis. Annual volumes are non-binding and contracts do not contain
minimum purchase guarantees. Price reductions are calculated on a per unit basis
and recognized as they occur.

COMMENT 4:

Note 2 - Business Combinations, page 47
Your note includes disclosures required by paragraph 54 of SFAS 141, however,
disclosures required by paragraphs 51 and 52 of SFAS 141 are omitted. As such,
please revise your financial statements to include all the information required
by SFAS 131. See paragraph C2 within Appendix C of SFAS 141 for guidance. We
believe that these disclosures requirements are applicable as long as the period
of acquisition is presented.

RESPONSE: We assume that the reference to SFAS 131 in the above comment was
meant to reference SFAS 141 and have responded accordingly below.

On June 21, 2004, Micron Merger Corporation, a newly formed entity and
wholly-owned subsidiary of Micron Holdings, Inc. merged with and into Titan
Holdings, Inc. ("Titan") with Titan continuing as the surviving Corporation. As
a result, Titan became a wholly-owned subsidiary of Micron, and remained the
parent of Autocam Corporation.

The Company believes that many of the disclosures required under paragraph 51 in
regard to the above merger have been satisfied as summarized below:

     o    Paragraph 51 (a) - The name and brief description of the acquired
          entity and the percentage of voting equity interests acquired.
          Disclosure - Footnote 1 to the audited financial statements included
          in the Form 10-K indicates that 100% of the Company was acquired
          through the merger and summarizes the investors that made common
          equity contributions.

     o    Paragraph 51 (b) - The primary reasons for the acquisition, including
          a description of the factors the contributed to a purchase price that
          results in recognition of goodwill.

          Disclosure - Footnote 1 to the audited financial statements included
          in the Form 10-K indicates that the merger was completed to facilitate
          the sale of the Company to two private equity sponsors for financial
          investment purposes

     o    Paragraph 51 (c) - The periods for which the results of operation of
          the acquired entity are included in the income statement of the
          combined entity.
          Disclosure - The transaction date of the merger is indicated in
          footnote 1 to the audited financial statements included in the Form
          10-K.

     o    Paragraph 51 (d) - the cost of the acquired entity and, if applicable,
          the number of share of equity interest (such as common shares,
          preferred shares, or partnership interests) issued or issuable, the
          value assigned to those interests, and the basis for determining
          value.
          Disclosure - The purchase price of $395 million has been disclosed in
          footnote 1 to the audited financial statements included in the Form
          10-K, and the equity structure has been disclosed in face of the
          balance sheet and the statement of shareholders' equity.

     o    Paragraph 51 (e) - A condensed balance sheet disclosing the amount
          assigned to each major asset and liability caption of the acquired
          entity at the acquisition date.
          Disclosure - The Company has also disclosed significant components of
          the assets acquired and liabilities assumed in either footnote 1 or
          footnote 2 to the audited financial statements included in the Form
          10-K, including the following: Borrowings under senior subordinated
          notes, borrowings under the senior credit facilities, equity
          contributions, and goodwill.

     o    Paragraph 51 (f) - Contingent payments, options, or commitments
          specified in the acquisition agreement and the accounting treatment
          that will be followed should any such contingency occur.
          Disclosure - No disclosure has been made as the purchase price did not
          include any contingent payments, options or other commitments.

     o    Paragraph 51 (g) - The amount of purchased research and development
          assets acquired and written off in the period and the line item in the
          income statement in which the amounts written off are aggregated.
          Disclosure - No disclosure has been made as there were no research and
          development assets acquired in the merger.

     o    Paragraph 51 (h) - For any purchase price allocation that has not been
          finalized, that fact and the reasons therefore. In subsequent periods,
          the nature and amount of any material adjustments made to the initial
          allocation of the purchase price shall be disclosed.
          Disclosure - No disclosure has been made as the purchase price
          allocation was finalized as of June 30, 2004 without any material
          adjustments to the initial allocation.

Paragraph 52 of SFAS 141 requires disclosures relating to goodwill and other
intangible assets. The Company recorded $249.4 million in goodwill in connection
with its revaluation of assets and liabilities. The value of goodwill was
disclosed, along with the allocation of goodwill among Autocam's operating
segments, in footnote 2 to the audited financial statements included in Form
10-K. The Company did not record any other material intangible assets.

We will incorporate the disclosure requirements of SFAS141 in all future filings
in the year an acquisition is disclosed, as applicable.

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As also requested in your letter of July 10, 2006, we acknowledge the following:

     o    The Company is responsible for the adequacy and accuracy of the
          disclosure in the filing;

     o    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

     o    The Company may not assert comments as a defense in any proceeding
          initiated by the Commission or any person under the federal securities
          laws of the United States.

Regards,

AUTOCAM CORPORATION


/s/ Warren A. Veltman
Warren A. Veltman
Chief Financial Officer

  
Cc:  Mr. Juan Migone, Securities and Exchange Commission, Division of Corporate Finance
     Ms. Margery Reich, Securities and Exchange Commission, Division of Corporate Finance