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                             August 29, 2022

       Aaron Ravenscroft
       President and Chief Executive Officer
       MANITOWOC CO INC
       11270 West Park Place
       Suite 1000
       Milwaukee, Wisconsin 53224

                                                        Re: MANITOWOC CO INC
                                                            Form 10-K for
Fiscal Year Ended December 31, 2021
                                                            Filed February 22,
2022
                                                            Form 10-Q for
Fiscal Quarter Ended June 30, 2022
                                                            Filed August 5,
2022
                                                            File No. 001-11978

       Dear Mr. Ravenscroft:

              We have limited our review of your filings to the financial
statements and related
       disclosures 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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for Fiscal Year Ended December 31, 2021

       Item 7. Management's Discussion and Analysis of Financial Condition and
Operating Results ,
       page 24

   1.                                                   You disclose in your
investor presentation on August 5, 2022 that inflation is shifting
                                                        from commodities to
labor, energy and components. Please discuss and analyze
                                                        the impact of this
shift in inflation as well as any price increases on your operating
                                                        results. Also discuss
and analyze your financial condition and changes in your financial
                                                        condition, and to the
extent applicable, the impact of inflation. Refer to Item 303(b) of
                                                        Regulation S-K.
 Aaron Ravenscroft
MANITOWOC CO INC
August 29, 2022
Page 2
Critical Accounting Policies and Estimates
Goodwill, Other Intangible Assets and Other Long-Lived Assets, page 36

2.       The book value of your shareholders    equity exceeded your market
capitalization at June
         30, 2022 and December 31, 2021 and your market capitalization declined
further for the
         six month period ended June 30, 2022. You changed the method to
perform your
         goodwill impairment assessment for the year ended December 31, 2021
and you now use
         the income approach and market approach, weighted 70/30 to determine
the fair value of
         each reporting unit. Please provide the following information:

                Tell us how you considered the qualitative factors outlined in
ASC 350-20-35-3C;
                Tell us the assumed revenue growth rates and the terminal
growth assumption;
                Tell us whether you would have recognized goodwill impairment
of any of your
              reporting units if you had continued to utilize the same income
approach you used to
              determine fair value in prior periods;
                Tell us how you determined the 70/30 weighting applied to the
income and market
              approaches to determine the fair value of your reporting units
and whether you would
              have recognized goodwill impairment if you had used a different
weighting;
                Tell us whether or not you performed an interim goodwill
impairment test during the
              six months ended June 30, 2022; and,
                Consider disclosing the percentages by which the estimated fair
values of each of
              your reporting units exceeded their carrying values at the date
of your impairment
              testing.

       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.

      You may contact Sondra Snyder, Senior Staff Accountant at (202) 551-3332
or Gus
Rodriguez, Accounting Branch Chief at (202) 551-3752 with any questions.



FirstName LastNameAaron Ravenscroft                          Sincerely,
Comapany NameMANITOWOC CO INC
                                                             Division of
Corporation Finance
August 29, 2022 Page 2                                       Office of Energy &
Transportation
FirstName LastName