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                              September 5, 2023

       Ernest Garcia, III
       Chief Executive Officer
       Carvana Co.
       300 E. Rio Salado Parkway
       Tempe, Arizona 85281

                                                        Re: Carvana Co.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            Filed February 23,
2023
                                                            Form 8-K Filed July
19, 2023
                                                            File No. 1-38073

       Dear Ernest Garcia:

              We have reviewed your filing 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 the Fiscal Year Ended December 31, 2022

       Note 10. Debt Instruments
       Long-Term Debt, page 104

   1.                                                   We note your indentures
contain restrictive covenants that limit your ability to pay
                                                        dividends and make
other distributions. Please tell us your consideration of the
                                                        disclosures in Rule
4-08(e)(3)(ii) of Regulation S-X and providing the condensed financial
                                                        information pursuant to
Rules 5-04 and 12-04 of Regulation S-X.
       Form 8-K Filed July 19, 2023

       Exhibit 99.2, page 1

   2.                                                   Your headline states
that you have delivered the best quarter in company history for
                                                        adjusted EBITDA and
total gross profit per unit. Please revise future filings to present an
 Ernest Garcia, III
Carvana Co.
September 5, 2023
Page 2
         equally prominent descriptive characterization of the comparable GAAP
measure, net
         income. Refer to the guidance in Question 102.10 of the Compliance and
Disclosure
         Interpretations for Non-GAAP Financial Measures.
        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 Tony Watson at (202) 551-3318 or Joel Parker at (202)
551-3651 if you
have questions.



FirstName LastNameErnest Garcia, III                       Sincerely,
Comapany NameCarvana Co.
                                                           Division of
Corporation Finance
September 5, 2023 Page 2                                   Office of Trade &
Services
FirstName LastName