United States securities and exchange commission logo





                            November 3, 2020

       Kevin Hearde
       Executive Vice President & Chief Financial Officer
       MARAVAI LIFESCIENCES HOLDINGS, INC.
       10770 Wateridge Circle Suite 200
       San Diego, California 92121

                                                        Re: MARAVAI
LIFESCIENCES HOLDINGS, INC.
                                                            Registration
Statement on Form S-1
                                                            Filed October 29,
2020
                                                            File No. 333-249733

       Dear Mr. Hearde:

              We have reviewed your registration statement and have the
following comment. In our
       comment 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 comment applies 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 this comment, we may have additional comments.

       Form S-1 filed October 29, 2020

       Exhibits

   1.                                                   We note your statement
on page 26 that Pfizer accounted for 14% of total revenue for the
                                                        nine months ended
September 30, 2020. Please file your agreement(s) with Pfizer
                                                        pursuant to Item
601(b)(10) of Regulation S-K or advise us regarding the basis for your
                                                        determination the
agreement(s) are not required to be filed as amendments. .
               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.

              Refer to Rules 460 and 461 regarding requests for acceleration.
Please allow adequate
       time for us to review any amendment prior to the requested effective
date of the registration
 Kevin Hearde
MARAVAI LIFESCIENCES HOLDINGS, INC.
November 3, 2020
Page 2

statement.

       You may contact Christine Torney at 202-551-3652 or Lynn Dicker at
202-551-3616 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Laura Crotty at 202-551-7614 or Suzanne Hayes at 202-551-3675 with any
other
questions.



                                                          Sincerely,
FirstName LastNameKevin Hearde
                                          Division of Corporation Finance
Comapany NameMARAVAI LIFESCIENCES HOLDINGS, INC.
                                          Office of Life Sciences
November 3, 2020 Page 2
cc:       Robert Hayward
FirstName LastName