November 15, 2018

Kevin C. Nash
Chief Financial Officer
Gentex Corporation
600 N. Centennial Street
Zeeland, Michigan 49464

       Re: Gentex Corporation
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed February 21, 2018
           Form 10-Q for the Quarterly Period Ended September 30, 2018
           Filed November 2, 2018
           File No. 000-10235

Dear Mr. Nash:

       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-Q for the Quarterly Period Ended September 30, 2018

Note 14 - Revenue, page 17

1.    We note your disclosure that contracts with original equipment
manufactures (OEM)
      generally include Long Term Supply Agreements, and that costs incurred to
fulfill these
      contracts are accounted for under ASC 340-10. Please expand to disclose
whether such
      costs are reimbursable, not reimbursable, or included in the pricing
consideration, and
      whether you expense or capitalize such costs. Also disclose the amount of
such contract
      costs, if material and where it is classified in the financial
statements. Reference is made
      to ASC 340-10-S99-3.
 Kevin C. Nash
Gentex Corporation
November 15, 2018
Page 2
2.       We note your disclosure that the company does not generate revenue
from arrangements
         with multiple deliverables. Please explain to us how you identify the
performance
         obligation(s) in contracts that include Long Term Supply Agreements.


       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.

      You may contact Beverly Singleton at (202) 551-3328 or Claire Erlanger at
(202) 551-
3301 with any questions.



FirstName LastNameKevin C. Nash                            Sincerely,
Comapany NameGentex Corporation
                                                           Division of
Corporation Finance
November 15, 2018 Page 2                                   Office of
Transportation and Leisure
FirstName LastName