November 26, 2024

Christopher Eperjesy
Chief Financial Officer
Custom Truck One Source, Inc.
7701 Independence Ave
Kansas City, MO 64125

       Re: Custom Truck One Source, Inc.
           Form 8-K filed October 30, 2024
           Response dated August 16, 2024
           File No. 1-38186
Dear Christopher Eperjesy:

       We have reviewed your filing and have the following comment(s).

       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 filed October 30, 2024
Exhibit 99.1, page 1

1.     We note your response to prior comment 2. The adjustments for Non-cash
purchase
       accounting impact and Sales-type lease adjustment in your reconciliation
of Adjusted
       EBITDA as a non-GAAP performance measure result in a misleading measure
that
       does not comply with Rule 100(b) of Regulation G. As such, Adjusted
EBITDA, as
       currently calculated, should no longer be presented as a non-GAAP
performance
       measure in future filings and other disclosures.
        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.

       Please contact Tony Watson at 202-551-3318 or Adam Phippen at
202-551-3336 if
you have questions regarding comments on the financial statements and related
matters.
 November 26, 2024
Page 2



                    Sincerely,

                    Division of Corporation Finance
                    Office of Trade & Services