April 2, 2019

Tara Comonte
Chief Financial Officer
Shake Shack Inc.
225 Varick Street, Suite 301
New York, New York 10014

       Re: Shake Shack Inc.
           Form 10-K for the Fiscal Year Ended December 26, 2018
           Filed February 25, 2019
           File No. 001-36823

Dear Ms. Comonte:

       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-K for the Fiscal Year Ended December 26, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Fiscal 2019 Guidance, page 57

1.    We note thatunder both the Fiscal 2019 Guidance, your preliminary
financial outlook for
      the fiscal year ending December 25, 2019 and, under Fiscal 2020 Targets,
you provide
      targeted total revenue for 2020, as well as several other measures.
Please expand both
      tables to also disclose the expected range or amount of pre-tax income
(loss) and/or net
      income (loss) and related per share amounts. Reference is made to Item
10(b)(2) of
      Regulation S-K, where presenting revenue projections without a measure of
income may
      bemisleading. In addition, for each of these two tables, provide a
narrative as to whether
      the section Trends in Our Business beginning on page 54 are the basis of
management's
      assumptions used to prepare these projections. Further, please provide
narrative
      disclosure that investors should be cautioned against attributing undue
certainty to
      management's assessment, indicate management's intention regarding the
furnishing of
 Tara Comonte
Shake Shack Inc.
April 2, 2019
Page 2
         updated projections, and consider all of the disclosure guidance in
Item 10(b)(3) of
         Regulation S-K.
2.       Additionally, we note that as part of your Fiscal 2019 guidance, you
provide shack-level
         operating profit margin and adjusted pro forma effective tax rate, two
non-GAAP
         financial measures. Please revise to include the appropriate non-GAAP
disclosures
         required by Item 10(e), including a reconciliation of this projected
range, to the
         appropriate amounts calculated in accordance with GAAP or provide
disclosure that you
         are relying on the "unreasonable efforts" exception in Item
10(e)(1)(I)(B). See Question
         102.10 of the SEC Staff's Compliance and Disclosure Interpretations on
Non-GAAP
         Financial Measures, updated April 4, 2018. Similarly, please make
these revisions in your
         earnings release filed on Form 8-K.
Non-GAAP Financial Measures, page 65

3.       Refer to the section of Adjusted Pro Forma Net Income and Adjusted Pro
Forma Earnings
         Per Fully Exchanged and Diluted Share that begins on page 67. Please
expand your
         tabular disclosure to reconcile Adjusted pro forma earnings per fully
exchanged share-
         diluted to the most directly comparable GAAP measure of earnings
(loss) per share of
         Class A common stock . You may choose to present such reconciliation
of the per share
         amount in a separate table. We refer you to Question 102.05 of the
Staff's Compliance
         and Disclosure Interpretations on Non-GAAP Financial Measures (last
update: April 4,
         2018).


       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 LastNameTara Comonte                                Sincerely,
Comapany NameShake Shack Inc.
                                                              Division of
Corporation Finance
April 2, 2019 Page 2                                          Office of
Transportation and Leisure
FirstName LastName