United States securities and exchange commission logo June 1, 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, 2022 File No. 001-12744 Dear Mr. Nickolas: We have limited our review of your filing to the financial statements and related disclosures 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, 2021 Properties, page 27 1. We note your disclosure of resources and reserves as values based on your average selling price per ton. Please restate your resources and reserves as tonnages to align with your definitions and the definitions at Item 1300 of Regulation S-K. 2. We note your resource and reserve disclosure does not include the price used to determine your economic resources and reserves. See footnote to Table 1 & 2 to Item 1303(b)(3) of Regulation S-K. 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. James A. J. Nickolas Martin Marietta Materials Inc. June 1, 2022 Page 2 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 June 1, 2022 Page 2 Office of Energy & Transportation FirstName LastName