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                               August 9, 2023

       David H. Watson
       Chief Executive Officer
       Argan, Inc.
       One Church Street
       Suite 201
       Rockville, MD 20850

                                                        Re: Argan, Inc.
                                                            Definitive Proxy
Statement on Schedule 14A
                                                            Filed May 1, 2023
                                                            File No. 001-31756

       Dear David H. Watson:

               We have limited our review of your most recent definitive proxy
statement to those issues
       we have addressed in our comments. Please respond to these comments by
confirming that you
       will revise your future proxy disclosures in accordance with the topics
discussed below.

       Definitive Proxy Statement on Schedule 14A filed May 1, 2023

       Pay Versus Performance, page 54

   1.                                                   Please revise the table
that provides a reconciliation of the adjustments to the totals as
                                                        presented in the
Summary Compensation Table to compensation actually paid to show
                                                        each of the numerical
amounts deducted and added pursuant to Regulation S-K Item
                                                        402(v)(2)(iii). We note
that you have provided one line item in the Summary
                                                        Compensation Table for
vested and unvested stock-based awards. See Regulation S-K
                                                        Item 402(v)(3). For
guidance, refer to Regulation S-K Compliance and Disclosure
                                                        Interpretations
Questions 128D.03 and 128D.04.
   2.                                                   We note that you have
included EBITDA as a percentage of Revenues, a non-GAAP
                                                        measure, as your
Company-Selected Measure pursuant to Regulation S-K Item
                                                        402(v)(2)(vi). Please
provide disclosure showing how this number is calculated from your
                                                        audited financial
statements, as required by Regulation S-K Item 402(v)(2)(v). We note
                                                        your reference in
footnote (7) to further discussion in the Compensation Discussion and
                                                        Analysis, but we are
unable to locate disclosure showing how your Company-Selected
                                                        Measure is derived from
the audited financial statements. If the required disclosure
                                                        appears in a different
part of the definitive proxy statement, you may satisfy the disclosure
                                                        requirement by a
cross-reference thereto; however, incorporation by reference to a
 David H. Watson
Argan, Inc.
August 9, 2023
Page 2
         separate filing will not satisfy this disclosure requirement.
       Please contact Isabel Rivera at 202-551-3518 or Amanda Ravitz at
202-551-3412 with
any questions.



FirstName LastNameDavid H. Watson                               Sincerely,
Comapany NameArgan, Inc.
                                                                Division of
Corporation Finance
August 9, 2023 Page 2                                           Disclosure
Review Program
FirstName LastName