September 17, 2024

Kevin Herde
Chief Financial Officer
MARAVAI LIFESCIENCES HOLDINGS, INC.
10770 Wateridge Circle
Suite 200
San Diego, CA
92121

       Re: MARAVAI LIFESCIENCES HOLDINGS, INC.
           Form 10-K for the Year Ended December 31, 2023
           File No. 001-39725
Dear Kevin Herde:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

Management's Discussion and Analysis of Financial Condition and Results of
Operations
General

1.     We acknowledge your response to our prior comment two. Based on the
information
       provided, the retention payments negotiated in the acquisitions of
MyChem and
       Alphazyme appear to be normal, recurring operating expenses necessary to
operate your
       business. As such, we believe the adjustments for the retention payments
are not
       consistent with Question 100.01 of the Compliance and Disclosurre
Interpretations related
       to non-GAAP measures. Please remove the adjustments for retention
payments from your
       presentation of Adjusted EBITDA as a non-GAAP performance measure.
       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.
 September 17, 2024
Page 2

       Please contact Christine Torney at 202-551-3652 or Kevin Vaughn at
202-551-3494 with
any questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Life Sciences