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                            January 4, 2023

       Dr. Babak A. Taheri
       Chief Executive Officer
       Silvaco Group, Inc.
       4701 Patrick Henry Drive, Building #23
       Santa Clara, CA 95054

                                                        Re: Silvaco Group, Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted December
19, 2022
                                                            CIK No. 0001943289

       Dear Dr. Babak A. Taheri:

             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. Unless we note otherwise, our references to prior comments are
to comments in our
       October 22, 2022 letter.

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

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Impact of COVID-19, page 55

   1.                                                   We note your response
to prior comment 5. Please quantify any specific COVID-19
                                                        impact you have
experienced to your results of operations, financial condition and
                                                        relevant metrics.
 Dr. Babak A. Taheri
FirstName  LastNameDr. Babak A. Taheri
Silvaco Group, Inc.
Comapany
January    NameSilvaco Group, Inc.
        4, 2023
January
Page 2 4, 2023 Page 2
FirstName LastName
Financial Statements
2. Summary of Significant Accounting Policies
Revenue Recognition, page F-9

2.       Please expand your revenue recognition policy disclosure
         concerning device characterization, modeling and SIP integration
services to fully comply
         with the guidance found in ASC paragraphs 606-10-50-17 through
606-10-50-20.
       You may contact Joseph Kempf, Senior Staff Accountant, at (202) 551-3352
or
Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have
questions
regarding comments on the financial statements and related matters. Please
contact Alexandra
Barone, Staff Attorney, at (202) 551-8816 or Matthew Crispino, Staff Attorney,
at (202) 551-
3456 with any other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Technology
cc:      Gabriella Lombardi