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                           December 9, 2021

       Michael J. Roper
       Chief Executive Officer
       Muscle Maker, Inc.
       2600 South Shore Blvd., Suite 300
       League City, TX 77573

                                                        Re: Muscle Maker, Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed December 3,
2021
                                                            File No. 333-261497

       Dear Mr. Roper:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Donald
Field at 202-551-3680 with any questions.




                           Sincerely,


                           Division of Corporation Finance

                           Office of Trade & Services