December 18, 2018

Vance Chang
Chief Financial Officer
YogaWorks, Inc.
5780 Uplander Way
Culver City, CA 90230

       Re: YogaWorks, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2017
           Filed April 3, 2018
           Form 10-Q for the Fiscal Quarter Ended September 30, 2018
           Filed November 14, 2018
           File No. 001-38151

Dear Mr. Chang:

       We have reviewed your filings 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 Fiscal Year Ended December 31, 2017

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP financial measures, page 42

1.    We note that your Non-GAAP performance measures identified as "Adjusted
free cash
      flow" and "Studio-Level adjusted free cash flow," which you provide to
investors and
      others to understand and evaluate your Company's operating results in the
same manner
      as management and the Board. Since free cash flow is typically calculated
as cash flow
      from operations adjusted by capital expenditures, and your definition of
free cash flow
      differs from the typical definition per Question 102.07 of the April 2018
C&DI on Non-
      GAAP measures, please revise the title of these measures in future
filings to provide a
      more appropriate description.
 Vance Chang
YogaWorks, Inc.
December 18, 2018
Page 2
2.       Additionally, we note that you adjust for changes in deferred revenue
to determine your
         performance measures "Adjusted free cash flow," "Studio-level free
cash flow" and
         "Studio-Level EBITDA." It appears your treatment of deferred revenue
represents
         individually tailored accounting principles substituted for those in
GAAP. In future
         filings, please remove these adjustments from your performance measure
calculations here
         as well as in your earnings releases on Forms 8-K. See Question 100.04
of the updated
         Non-GAAP C&DIs.
        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 Joseph Cascarano, Staff Accountant, at (202) 551-3376
or Robert S.
Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact Paul
Fischer, Attorney-
Advisor, at (202) 551-3415 or Larry Spirgel, Assistant Director, at (202)
551-3815 with any
other questions.



FirstName LastNameVance Chang                               Sincerely,
Comapany NameYogaWorks, Inc.
                                                            Division of
Corporation Finance
December 18, 2018 Page 2                                    Office of
Telecommunications
FirstName LastName