SecProbe.io

October 10, 2024
Kevin Hostetler
Chief Executive Officer and Interim Chief Financial Officer
Array Technologies, Inc.
3901 Midway Place NE
Albequerque, New Mexico 87109
Re:Array Technologies, Inc.
Form 10-K for the Year Ended December 31, 2023
Form 8-K furnished August 8, 2024
File No. 001-39613
Dear Kevin Hostetler:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            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.
Form 8-K furnished August 8, 2024
Exhibit 99.1 Earnings Release , page 10
1.We note that your table on page 10 that reconciles Gross Profit to Adjusted Gross
Profit, includes disclosure of Adjusted Gross Margin. Please revise future filings to
include disclosure of GAAP Gross Margin whenever you include disclosure of
Adjusted Gross Margin.  See Question 102.10 of the SEC Staff’s Compliance and
Disclosure Interpretation on Non-GAAP Financial Measures.
Form 10-K for the Year Ended December 31, 2023
Management's Discussion of Financial Condition and Results of Operations
Results of Operations
Year Ended December 31, 2023 Compared to December 31, 2022, page 49
We note your disclosure that the $34.1 million, or 9%, revenue increase in STI
Operations in 2023 was driven by an increase in the number of megawatts shipped,
most notably in the Brazil region, which offset lower ASP, due to a smaller 2.

October 10, 2024
Page 2
percentage of construction services being offered.  We also note that As a percentage
of revenue, gross profit for STI Operations increased to 24% from 16% for the year
ended December 31, 2023 and 2022, respectively, driven primarily by improved pass
through of commodity volatility to customers, cost saving opportunities in raw
materials, and a reduced impact of lower margin construction-related services
provided.  When more than one factor contributes to the change in amount of a
specific income statement line item, such as revenue or gross profit, please revise your
discussion in future filings to quantify the amount related to each factor, to the extent
material.
Critical Accounting Estimates
Goodwill, page 53
3.We note your disclosure that during the fourth quarter of 2023, with the assistance of
a third-party specialist, you performed a quantitative assessment of the fair value of
your STI reporting unit using the DCF and GPC methods described in Note 7 –
Goodwill and Other Intangible Assets of the consolidated financial statements. Please
tell us and revise to clarify whether the fair value of the reporting unit significantly
exceeds the carrying value. To the extent any reporting unit is at risk of impairment,
please revise future filings to disclose the percentage by which the fair value exceeded
the carrying value and describe any potential events and/or changes in circumstances
that could reasonably be expected to negatively affect any key assumptions.
Notes to the Audited Financial Statements
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page F-21
4.We note that the majority of your revenue is recognized over time as work progresses,
and for single performance obligations, you use an input measure, the cost-to-cost
method, to determine progress.  We also note that you review and update the contract-
related estimates on an ongoing basis and recognize adjustments for any project
specific facts and circumstances that could impact the measurement of the extent of
progress such as the total costs to complete the contracts, under the cumulative catch-
up method.  Please tell us and quantify in the notes to your financial statements in
annual and quarterly reports the aggregate amount and related earnings per share
impact of changes in contract estimates for each period presented. Refer to ASC 250-
10-50-4 and 270-10-45-14 for guidance. Please also revise your results of operations
disclosure in MD&A to separately quantify gross favorable and gross unfavorable
changes in estimates material to either consolidated or segment results, accompanied
by an appropriate level of analysis. Please provide us with your intended revised
disclosure.

            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.

October 10, 2024
Page 3
            Please contact Claire Erlanger at 202-551-3301 or Kevin Woody at 202-551-3629
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing