March 7, 2019

Robert D. Kamphuis
Chairman, President & Chief Executive Officer
Mayville Engineering Company, Inc.
715 South Street
Mayville, WI 53050

       Re: Mayville Engineering Company, Inc.
           CONFIDENTIAL Draft Registration Statement on Form S-1
           Submitted February 8, 2019
           CIK No. 1766368

Dear Mr. Kamphuis:

       We have reviewed your draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

DRS S-1 Filed February 8, 2019

General, page i

1.     Please supplementally provide us with copies of all written
communications, as defined in
       Rule 405 under the Securities Act, that you, or anyone authorized to do
so on your behalf,
       present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
       not they retain copies of the communications.
The Offering, page 11

2.     We note disclosure in the last bullet of the Risk Factors section on
this page of the
       retroactive effect of a stock dividend to be paid in 2019. In this
section, please explain the
       stock dividend or provide a reference to disclosure in the registration
statement that
 Robert D. Kamphuis
Mayville Engineering Company, Inc.
March 7, 2019
Page 2
         explains the stock dividend.
Use of Proceeds, page 33

3.       We note your disclosure that the net proceeds may be used for future
acquisitions of
         businesses. Please revise to identify any planned acquisitions
pursuant to Instruction 6 of
         Item 504. Alternatively, if you have no current specific plan for the
proceeds, please so
         state.
Financial Statements, page F-1

4.       Please note that once you have provided updated financial information,
we will need
         sufficient time to review such information and may have additional
comments.
        You may contact Mindy Hooker (Staff Accountant) at (202) 551-3732 or
Kevin Stertzel
(Staff Accountant) at (202) 551-3723 if you have questions regarding comments
on the financial
statements and related matters. Please contact Sherry Haywood (Staff Attorney)
at (202) 551-
3345 or Jay Ingram (Legal Branch Chief) at (202) 551-3397 with any other
questions.



                                                               Sincerely,
FirstName LastNameRobert D. Kamphuis
                                                               Division of
Corporation Finance
Comapany NameMayville Engineering Company, Inc.
                                                               Office of
Manufacturing and
March 7, 2019 Page 2                                           Construction
FirstName LastName