September 23, 2019 Rajesh Vashist Chief Executive Officer SiTime Corporation 5451 Patrick Henry Drive Santa Clara, California 95054 Re: SiTime Corporation Amendment No. 3 to Draft Registration Statement on Form S-1 Submitted September 12, 2019 CIK No. 0001451809 Dear Mr. Vashist: 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. 3 to Draft Registration Statement on Form S-1 submitted September 12, 2019 Revenue, page 66 1. Please revise to explain the reasons underlying the lower sales volume from customers in Asia. Please also revise to describe in more detail the "downturn" referenced on page 2019 and its impact on your operations. You may contact Gary Newberry at 202-551-3761 or Kevin Kuhar, Accounting Branch Chief, at 202-551-3662 if you have questions regarding comments on the financial statements and related matters. Please contact Thomas Jones at 202-551-3602 or Geoffrey Kruczek, Special Counsel, at 202-551-3641 with any other questions. Rajesh Vashist SiTime Corporation September 23, 2019 Page 2 Sincerely, FirstName LastNameRajesh Vashist Division of Corporation Finance Comapany NameSiTime Corporation Office of Electronics and Machinery September 23, 2019 Page 2 cc: Jorge del Calvo, Esq. FirstName LastName