Mail Stop 3561
								January 9, 2008

Via Fax & U.S. Mail

Ms. Catherine D`Amico
Executive Vice President -Finance
Treasure and Chief Financial Officer
Monro Muffler Brake, Inc.
200 Holleder Parkway
Rochester, New York 14615

Re:	Monro Muffler Brake, Inc.
	Form 10-K for the year ended March 31, 2007
      	File No. 0-19357

Dear Ms. D`Amico

      We have reviewed your filing and have the following
comments.
Unless otherwise indicated, we think you should revise your future
filings in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

      Please respond to confirm that such comments will be
complied
with, or, if certain of the comments are deemed inappropriate,
advise
the staff of your reason.  Your response should be submitted in
electronic form, under the label "corresp" with a copy to the
staff.
Please respond within ten (10) business days.






Management`s Discussion and Analysis of Financial Condition and
Results of Operations
Fiscal 2007 Compared to Fiscal 2006
Fiscal 2006 Compared to Fiscal 2005

1. We note the disclosure in MD&A indicating that the Company
completed the bulk sale of approximately $3.9 million and $4.1
million of slower moving inventory to Icon International, a barter
company during fiscal 2007 and fiscal 2006, respectively. Please
tell
us and revise MD&A in future filings to disclose the significant
terms of this transaction including the nature and amount of the
consideration received in connection with the sale. Also, if non-
cash
consideration was received, please explain how it was valued by
the
Company. In addition, if these transactions had a material impact
on
the Company`s reported gross profits for the periods, please
revise
MD&A to discuss and quantify the impact of these transactions on
the
Company`s reported gross profits.

2. We note from the discussion on pages 19, 20 and 21 of MD&A that
other expense included $2.8 million, $1.0 million, and $1.4
million
in gains on the sale of fixed assets during fiscal 2007, 2006 and
2005, respectively. Note that gains on disposal of long-lived
assets
should be included as a component of income from operations as
required by paragraph 45 of SFAS No.144. Please revise your
consolidated statement of operations in future filings to comply
with
the requirements of SFAS No. 144.

Consolidated Statement of Changes in Shareholders` Equity, page 29
3. We note that you have presented the adjustment to initially
apply
the provisions of SFAS No.158 for pension benefits as a component
of
your other comprehensive income and total comprehensive income for
the fiscal year ended March 31, 2007. Please note that in
accordance
with paragraph 16a of SFAS No.158 and paragraph A7 of Appendix A
to
SFAS No.158, the effect of initially applying the provisions of
SFAS
No. 158 should be reported as an adjustment of the ending balance
of
accumulated other comprehensive income rather than as a component
of
other comprehensive income for the period. Please revise your
disclosures with regard to your other comprehensive income and
accumulated other comprehensive income for the year ended March
31,
2007, to comply with the guidance outlined in paragraph 16a of
SFAS
No.158 in any future filings.

Note 2 - Acquisitions
4. We note from the disclosure in Note 2 that the Company acquired
75
automotive maintenance and repair service stores throughout Ohio
and
Pennsylvania on April 29, 2006 for a purchase price of
approximately
$14.7 million. We also note from the disclosure in Note 5 that the
Company recognized approximately $15.2 million of goodwill in
connection with this acquisition. Please tell us and revise future
filings to disclose the primary reasons for the acquisition,
including a description of the factors that contributed to a
purchase
price that resulted in recognition of goodwill. Also, please
ensure
that future filings include all of the disclosures required by
paragraphs 51 and 52 of SFAS No. 141 with respect to this
acquisition, as applicable. These disclosures should include a
condensed balance sheet showing the amounts assigned to each asset
and liability caption of entity acquired, including any amounts
assigned to any intangible assets acquired, and the amount of
goodwill that is expected to be deductible for tax purposes. Your
disclosures with respect to the acquisition of Valley Forge Tire &
Auto Centers and Craven Tire and Auto during the first quarter of
fiscal 2008 should be similarly revised in any future filings.

Quarterly Reports on Form 10-Q for the quarters ended June 30,
2007
and September 29, 2007
Note 6. Supplemental Disclosure of Cash Flow Information
5. We note the disclosure indicating that the Company recorded
purchase accounting adjustments for the ProCare acquisition that
increased goodwill by $698,000, reduced fixed assets by
$1,592,000,
increased debt by $142,000, reduced current liabilities by
$31,000,
reduced long-term liabilities by $540,000 and increased long-term
deferred taxes by $465,000 during the six months ended September
29,
2007. Please tell us and explain in the notes to your financial
statements in future filings the facts or circumstances that
resulted
in these purchase price adjustments during the six months ended
September 29, 2007. As part of your response, you should also
explain
why these adjustments were required more than a year after the
completion of the ProCare acquisition. We may have further comment
upon receipt of your response.

Note 9. Other Items
6. We note the disclosure indicating that Auction Direct has
issued
warrants to Monro for the purchase of 2.5% of its existing equity.
We
also note that the warrants are reflected at zero value in the
Company`s consolidated financial statements at September 29, 2007.
Please tell us and explain in future filings why a zero value has
been assigned to these warrants.

Management`s Discussion and Analysis
First Quarter ended June 30, 2007 compared to First Quarter ended
June 24, 2006
7. We note from the discussion in MD&A that the increase in gross
profit for the quarter ended June 30, 2007 was due in part to a
shift
in vendor rebates from SG&A to cost of sales in the current
quarter
as compared to the prior year. Please tell us and explain in MD&A
in
future filings why more vendor rebates were reflected in cost of
sales in the current period versus SG&A in prior periods. We may
have
further comment upon receipt of your response.

Other
8. We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.


      You may contact  Linda Cvrkel at (202)551-3813 if you have
any
questions
      regarding comments on the financial statements and related
matters.


      Sincerely,



      Linda Cvrkel
      Branch Chief


Ms. Catherine D'Amico
Monro Muffler Brake, Inc
January 9, 2008
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