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, Inc. Draft Registration Statement Filed February 25, 2021 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 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. Draft Registration Statement Filed February 25, 2021 General 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- 1. 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 Manufacturing FirstName LastName