May 1, 2019

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

       Re: Mayville Engineering Company, Inc.
           Amendment No. 1 to Form S-1
           Filed April 29, 2019
           File No. 333-230840

Dear Mr. Kamphuis:

      We have reviewed your amended 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 amending your registration statement
and providing the
requested information. 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 any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our [Month day,
year] letter.

Form S-1/A filed April 29, 2019

Dilution, page 43

1.     Please revise your dilution calculation and related disclosures to
quantify the following:
       net tangible book value prior to the offering, the change in the net
tangible book value per
       share attributable to the offering, and the amount of immediate dilution
as a result the
       offering. Please reference Item 506 of Regulation S-K for guidance.
 Robert D. Kamphuis
Mayville Engineering Company, Inc.
May 1, 2019
Page 2

        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
May 1, 2019 Page 2                                        Construction
FirstName LastName