United States securities and exchange commission logo

                            March 1, 2021

       Jim Fusaro
       Chief Executive Officer
       Array Technologies, Inc.
       3901 Midway Place, NE
       Albuquerque, NM 87019

                                                        Re: Array Technologies,
                                                            Draft Registration
                                                            Filed February 25,
                                                            File No. 377-04310

       Dear Mr. Fusaro:

              We have reviewed your 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

             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

       Draft Registration Statement Filed February 25, 2021


   1.                                                   Because you have not
filed your Form 10-K for the fiscal year ended December 31, 2020,
                                                        which you seek to
incorporate by reference, your filing does not meet the requirements of
                                                        subparagraphs (e)-(j)
of Item 11 of Form S-1. The SEC's policy allowing for confidential
                                                        review of draft
registration statements does not permit the submission of a registration
                                                        statement that fails in
numerous respects to meet the requirements of the Form or
                                                        Regulation S-K. Please
amend your filing to include the information required by Form S-
 Jim Fusaro
Array Technologies, Inc.
March 1, 2021
Page 2

          Please contact Jay Ingram at 202-551-3397 with any other questions.

FirstName LastNameJim Fusaro                                Sincerely,
Comapany NameArray Technologies, Inc.
                                                            Division of
Corporation Finance
March 1, 2021 Page 2                                        Office of
FirstName LastName