United States securities and exchange commission logo May 20, 2022 Tyson Hottinger General Counsel Array Technologies, Inc. 3901 Midway Place NE Albuquerque, New Mexico 87109 Re: Array Technologies, Inc. CIK 0001820721 Form S-1 Filed May 13, 2022 File No. 333-264950 Dear Mr. Hottinger: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Alex King at 202-551-8631 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Michael Kim