United States securities and exchange commission logo

                             June 15, 2022

       Nipul Patel
       Chief Financial Officer
       Array Technologies, Inc.
       3901 Midway Place NE
       Albuquerque, New Mexico 87109

                                                        Re: Array Technologies,
                                                            Form 10-K for the
Year Ended December 31, 2021
                                                            Form 10-Q for the
Quarter Ended March 31, 2022
                                                            Form 8-K furnished
May 10, 2022
                                                            File No. 001-39613

       Dear Mr. Patel:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Year Ended December 31, 2021

       Risk Factors
       Significant changes in the cost of raw materials could adversely affect
our financial performance,
       page 20

   1.                                                   We note your risk
factor indicating that significant changes in commodity prices could
                                                        harm your business,
financial condition and results of operations which is also listed as a
                                                        summary risk factor in
your 10-Q for the quarter ended March 31, 2022. We further note
                                                        your MD&A discussion on
pages 47 and 50 of your 10-K concerning higher commodity
                                                        prices during 2021.
Please update this risk factor if recent commodity price changes have
                                                        materially impacted
your operations. In this regard, identify the types of commodity price
                                                        changes you have
experienced and how your business has been affected.
 Nipul Patel
FirstName  LastNameNipul
Array Technologies, Inc. Patel
June        NameArray Technologies, Inc.
     15, 2022
June 15,
Page 2 2022 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Critical Accounting Estimates, page 55

2.       We note your discussion of critical accounting estimates on page 55
and on page 41 of
         your 10-Q for the quarter ended March 31, 2022, that you believe
involve a significant
         level of estimation uncertainty and have had or are reasonably likely
to have a material
         impact on your financial condition or results of operations.
Considering goodwill and
         other intangible assets comprises approximately 50% of your total
assets, please tell us
         how you considered including a discussion of the significant estimates
and assumptions
         associated with your impairment analysis in your critical accounting
         disclosures. In this regard, please quantify and provide an analysis
of the impact of
         critical accounting estimates on your financial position and results
of operations for the
         periods presented, including the effect of changes in critical
accounting estimates between
         periods to the extent such changes had a significant effect on your
financial position or
         operating results. In addition, please revise to include a qualitative
and quantitative
         analysis of the sensitivity of reported results to changes in
assumptions, judgments, and
         estimates when reasonably likely changes in assumptions, judgments and
estimates would
         have a material effect on your financial condition or operating
performance. Refer to Item
         303(b)(3) of Regulation S-K.
Financial Statements
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Goodwill, page F-18

3.       Given the significant decline of your market capitalization and stock
price, please tell us
         the factors utilized to determine impairment was not required.
Specifically address the
         qualitative factors outlined in ASC 350-20-35-3C and include in your
response why your
         quantitative analysis did not result in impairment given your net
losses, negative cash
         flows, and stockholders    deficit. Tell us and consider disclosing
the percentages by which
         the estimated fair values exceed the carrying values at the date of
the your impairment
         test. Lastly, tell us if you performed interim impairment testing
during the three months
         ended March 31, 2022.
Revenue Recognition
Performance Obligations, page F-20

4.       You indicate that revenue will be recognized when all the specific
requirements for
         transfer of control under a bill-and-hold arrangement have been met.
In this regard, please
         revise your disclosure to clarify the following:
             The substantive reasons for the bill-and-hold arrangements;
             Whether the products are separately identified since they belong
to customers;
             Whether the products are ready for physical transfer to customers;
             Whether you have the ability to use the products or direct them to
other customers.
 Nipul Patel
FirstName  LastNameNipul
Array Technologies, Inc. Patel
June        NameArray Technologies, Inc.
     15, 2022
June 15,
Page 3 2022 Page 3
FirstName LastName
         Refer to ASC 606-10-55-83 and advise.
10. Convertible Debt
Capped Call, page F-35

5.       Please revise to disclose the significant terms of the capped call
instruments including
         how the requirements for equity classification under ASC 815-40 were
met. Your
         response and revised disclosure should include whether the agreements
covering these
         instruments have any early termination or settlement provisions.
Form 10-Q for the Quarter Ended March 31, 2022

Exhibits 31, page 1

6.       We note that the certifications under Item 601(b)(31) of Regulation
S-K of the principal
         executive officer and principal financial officer are not in the
proper form. Please amend
         your Form 10-Q to revise this certification to include the exact
language prescribed by
         Item 601(b)(31) of Regulation S-K. Specifically, please revise the
introductory language
         of paragraph 4 to refer to the certifying individual   s
responsibility for establishing and
         maintaining internal control over financial reporting in Exhibits 31.1
and 31.2.
Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Impact of Potential Solar Module Supply Chain Disruptions, page 33

7.       We note your discussion of the Impact of Potential Solar Module Supply
         Disruptions and that the related investigation has created uncertainty
and is expected to
         disrupt the solar panel supply chain in the near-term, which could
negatively impact the
         global solar market and could have a material adverse effect on your
business, financial
         condition and results of operations. We further note that on your Q1
2022 earnings call,
         you quantified an estimated impact to revenue for the remainder of
2022 for the related
         expected impact to your business. Revise to specify whether these
challenges have
         materially impacted your historical results of operations or capital
resources and quantify,
         to the extent possible, how your sales, profits, and/or liquidity have
         impacted. Further, tell us your consideration for disclosing the
respective future impacts
         as you quantified on your earnings call. Refer to Items 303(b)(1) and
303(b)(2) and of
         Regulation S-K.
8.       In a related matter, we note your disclosure of impacts from commodity
price increases
         and strained logistics, including those disclosed on page 39 and
certain modification
         processes you described on page 35. Please revise to further discuss
known trends or
         uncertainties resulting from these mitigation efforts undertaken for
your supply chain
         disruptions including those you discussed on your earnings call.
Explain whether any
         mitigation efforts introduce new material risks, including those
related to product quality,
         reliability, or regulatory approval of products.
 Nipul Patel
Array Technologies, Inc.
June 15, 2022
Page 4
Form 8-K furnished May 10, 2022

Exhibit 99.1, page 1

9.       The bullet points at the top of the page report adjusted basic and
diluted net loss per share
         without presentation of the most directly comparable GAAP measure.
Please revise to
         present basic and diluted net loss per share under GAAP with equal or
greater prominence
         in accordance with Instruction 2 of Item 2.02 of Form 8-K and Item
10(e)(1)(i)(A) of
         Regulation S-K.
10.      In a related matter, please revise to include a reconciliation of net
loss per share to
         adjusted net loss per share for each respective period in accordance
with Item
         10(e)(1)(i)(B) of Regulation S-K.
       In closing, 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.

       You may contact Heather Clark at 202-551-3624 or Melissa Gilmore at
with any questions.

FirstName LastNameNipul Patel                                    Sincerely,
Comapany NameArray Technologies, Inc.
                                                                 Division of
Corporation Finance
June 15, 2022 Page 4                                             Office of
FirstName LastName