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February 14, 2024
Christopher Eperjesy
Chief Financial Officer
Custom Truck One Source, Inc.
7701 Independence Ave
Kansas City, MO 64125
Re:Custom Truck One Source, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Response dated December 15, 2023
File No. 1-38186
Dear Christopher Eperjesy:
            We have reviewed your December 15, 2023 response to our comment letter and have the
following comment(s).
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our December 1, 2023
letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Adjusted EBITDA, page 28
1.We note your response to prior comment 2 regarding Adjusted EBITDA and we re-issue
our previous comment. Please revise your presentation in future filings to remove the
purchase accounting and sales-type lease adjustments as they change the recognition and
measurement principles required to be applied in accordance with GAAP. Refer to
Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure
Interpretations.

 FirstName LastNameChristopher Eperjesy
 Comapany NameCustom Truck One Source, Inc.
 February 14, 2024 Page 2
 FirstName LastName
Christopher Eperjesy
Custom Truck One Source, Inc.
February 14, 2024
Page 2
            Please contact Tony Watson at 202-551-3318 or Adam Phippen at 202-551-3336 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services