Abstract.The relationship between pullback velocity and impact velocity is studied for different microstructures in Cu. A size distribution of potential nucleation sites is derived under the conditions of an applied stochastic stress field. The size distribution depends on flow stress leading to a connection between the plastic flow appropriate to a given microstructure and nucleation rate. The pullback velocity in turn depends on the nucleation rate resulting in a prediction for the relationship between pullback velocity and flow stress. The theory is compared to observations of Cu on Cu gasgun experiments (10 -50 GPa) for a diverse set of microstructures. The scaling law is incorporated into a 1D finite difference code and is shown to reproduce the experimental data with one adjustable parameter that depends only on a nucleation exponent, Γ.