December 9, 2019

Michael J. Roper
Chief Executive Officer
Muscle Maker, Inc.
308 East Renfo Street, Suite 101
Burleson, Texas 76028

       Re: Muscle Maker, Inc.
           Registration Statement on Form S-1
           Filed November 26, 2019
           File No. 333-235283
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted November 15, 2019
           CIK No. 0001701756

Dear Mr. Roper:

       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
response.

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

Form S-1 filed November 26, 2019

Management's Discussion and Analysis, page 39

1.     We note your response to prior comment 3. However, we do not see
quantified
       comparable restaurant sales and growth figures for historical periods
disclosed, even if in
       the negative percentage range. Please revise to provide this disclosure
so that readers can
       appreciate the direction in which this metric is headed and why or
advise us why you
       believe this disclosure is not material to investors.
 Michael J. Roper
FirstName LastNameMichael J. Roper
Muscle Maker, Inc.
Comapany9, 2019
December NameMuscle Maker, Inc.
Page 2
December 9, 2019 Page 2
FirstName LastName

Consolidated Results of Operations, page 41

2.       You refer to your anticipated "2% comparable same store sales increase
year-over-year"
         derived from your future financial projection model. Without
understanding the
         assumptions that underlie this reference, it is inappropriate for you
to project this amount.
         Either revise your prospectus to provide the assumptions that underlie
this percentage or
         revise to remove it. Refer to Item 10(b) of Regulation S-K.
Summary Compensation Table, page 69

3.       We note your response to prior comment 7. We are having trouble
reconciling the
         narrative information you provide in footnote (3) to the Summary
Compensation Table
         with the values reflected in the table itself. Please revise or
advise. We also note your
         description of Rodney C. Silva's stock awardson page 73. Please revise
to explain how
         you arrived at the amounts you granted.
Interim September 30, 2019 Financial Statements
Condensed Consolidated Balance Sheets, page F-1

4.       We note that the December 31, 2018 balance sheet presented with your
September 30,
         2019 interim financial statements on page F-1 does not agree with
December 31, 2018
         balance sheet presented with your annual financial statements on page
F-30. Please revise
         as appropriate.
General

5.       We note your response to comment 10 and your expectation that the 15%
Senior Secured
         Convertible Promissory Notes and 12% Secured Convertible Promissory
Notes are being
         renegotiated and are expected to be fully converted prior to the
offering. Please ensure
         you revise both prospectuses to reflect the terms of the
renegotiation. As a related matter,
         please tell us why the "Number of Shares of Common Stock" column entry
for Secured
         and Collateralized Lending, LLC doesn't reflect a higher number of
shares, as suggested
         by footnote (1) or revise.
        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.

       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
statement.
 Michael J. Roper
Muscle Maker, Inc.
December 9, 2019
Page 3

       You may contact Patrick Kuhn, Staff Accountant at 202-551-3308 or Doug
Jones, Staff
Accountant at 202-551-3309 if you have questions regarding comments on the
financial
statements and related matters. Please contact Scott Anderegg, Staff Attorney
at 202-551-3342
or Mara Ransom, Office Chief at 202-551-3264 with any other questions.



FirstName LastNameMichael J. Roper                        Sincerely,
Comapany NameMuscle Maker, Inc.
                                                          Division of
Corporation Finance
December 9, 2019 Page 3                                   Office of Trade &
Services
FirstName LastName