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                              August 3, 2022

       James A. J. Nickolas
       Senior Vice President and Chief Financial Officer
       Martin Marietta Materials Inc.
       2710 Wycliff Road
       Raleigh, North Carolina

                                                        Re: Martin Marietta
Materials Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Filed February 22,
                                                            File No. 001-12744

       Dear Mr. Nickolas:

              We have reviewed your July 11, 2022 response to our comment
letter 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
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       June 27, 2022 letter.

       Form 10-K

       Properties, page 27

   1.                                                   We note your response
to comment 1 that the 2021 January through December regional
                                                        average selling price
is a reasonable and justifiable price to estimate your Company   s
                                                        mineral reserves and
mineral resources. Your resource/reserve estimates may not be
                                                        compliant as the
qualified persons estimating your resources and reserve must disclose the
                                                        prices used to prepare
their estimates establishing economic viability within the prescribed
                                                        accuracy limits for
each of your properties. This may require your 267 technical report
                                                        summaries to have a
cash flow analysis prepared for each of your properties after the
                                                        fiscal year end, which
may not be possible or allow for timely periodic filings. For your
                                                        information, many other
companies use a historic average based on the previous year or
                                                        multiple years. Please
revise your disclosure to disclose how you determined your
 James A. J. Nickolas
Martin Marietta Materials Inc.
August 3, 2022
Page 2
         reasonable and justifiable prices and specify the timeframe of your
         prices. See Item 1302(e)(3) and Item 1302(e)(4) of Regulation S-K.
      You may contact Ken Schuler, Mine Engineer, at (202)551-3718 or Craig
Arakawa, Accounting Branch Chief, at (202)551-3650 with any questions.

FirstName LastNameJames A. J. Nickolas                        Sincerely,
Comapany NameMartin Marietta Materials Inc.
                                                              Division of
Corporation Finance
August 3, 2022 Page 2                                         Office of Energy
& Transportation
FirstName LastName