United States securities and exchange commission logo

                          March 11, 2021

       George Chamoun
       Chief Executive Officer
       ACV Auctions Inc.
       640 Ellicott Street, #321
       Buffalo, New York 14203

                                                        Re: ACV Auctions Inc.
Statement on Form S-1
                                                            Filed February 26,
                                                            File No. 333-253617

       Dear Mr. Chamoun:

              We have reviewed your 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

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-1 filed February 26, 2021

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Impact of COVID-19 on Our Business
       Adjusted EBITDA, page 65

   1.                                                   We note your disclosure
of Adjusted EBITDA on a quarterly basis. In accordance with
                                                        Item 10(e) of
Regulation S-K, please reconcile your quarterly non-GAAP financial
                                                        measures to the most
directly comparable GAAP measure.

               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.
 George Chamoun
ACV Auctions Inc.
March 11, 2021
Page 2

       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

       You may contact Scott Stringer at 202-551-3272 or Angela Lumley at
202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Scott Anderegg at 202-551-3342 or Dietrich King at 202-551-8071 with
any other

FirstName LastNameGeorge Chamoun
                                                           Division of
Corporation Finance
Comapany NameACV Auctions Inc.
                                                           Office of Trade &
March 11, 2021 Page 2
cc:       Alan Hambelton
FirstName LastName