July 23, 2019

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, 2018
           Filed March, 27 2019
           Form 10-Q for Fiscal Quarters Ended March 31, 2019
           Filed May 14, 2019
           File No. 001-38151

Dear Mr. Chang:

      We have reviewed your filing and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your
disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 10-Q for Fiscal Quarters Ended March 31, 2019

Liquidity and Capital Resources
Selected Cash Flow Data, page 22

1.    We note your presentation of a Non-GAAP measure called Adjusted studio
operating cash
      flows, which we discussed on our call of June 5, 2019. Please revise
future periodic
      filings and eliminate the measure as Adjusted studio operating cash flows
violates
      Item 10(e)(1)(ii)(A) of Regulation S-K because it excludes charges or
liabilities that
      required, or will require, cash settlement.
        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.
 Vance Chang
YogaWorks, Inc.
July 23, 2019
Page 2

        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
July 23, 2019 Page 2                                       Office of
Telecommunications
FirstName LastName