August 5, 2019

Greg Halpern
Chief Financial Officer
Max Sound Corporation
3525 Del Mar Heights Road #802
San Diego, CA 92130

       Re: Max Sound Corporation
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed March 29, 2019
           Form 10-Q for the Quarterly Period Ended March 31, 2019
           Filed May 14, 2019
           File No. 000-51886

Dear Mr. Halpern:

       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 31, 2018

Item 9A. Controls and Procedures

1.    Please revise to state that you concluded your disclosure controls and
procedures were
      effective as of December 31, 2018. Also, state, if true, that your
internal controls over
      financial reporting were effective as of December 31, 2018 (as opposed to
December 31,
      2017 as you currently indicate), and that there were no changes during
the quarter ended
      this same date.
Report of Independent Registered Public Accounting Firm

2.    We note that G.A. Wahl is not registered with the PCAOB. As such, you may
not include
      an audit report from this firm in your filings until their registration
process is complete. In
      addition, G.A. Wahl's report indicates that they have served as the
company's auditor
 Greg Halpern
Max Sound Corporation
August 5, 2019
Page 2
         since 2015; however, it appears from reports included in your previous
Form 10-K filings
         that Anton & Chia, LLP were the company's auditors since 2015. Please
amend your
         December 31, 2018 Form 10-K to include financial statements that have
been audited by a
         PCAOB registered firm.
3.       To the extent there has been a change in your independent registered
accounting firm,
         please note that you were required to file an Item 4.01 Form 8-K along
with an Exhibit 16
         letter from your former accountant within four business days after the
occurrence of such
         event. Refer to General Instruction B to Form 8-K and Item 304 of
Regulation S-K, and
         file the Form 8-K accordingly. In addition, address Item 9 of Form
10-K in your
         amendment.
Exhibits 31.2 & 32

4.       Please ensure that the certifications are correctly signed and dated
when you file the Form
         10-K/A. In this regard, we note that Mr. Halpern's Section 302
Certification is dated
         March 29, 2018. We also note that Mr. Blaisure did not properly sign
the Section 906
         certification.
Form 10-Q for the Quarterly Period Ended March 31, 2019

Exhibit 32

5.       Please amend to include revised certifications pursuant to Section 906
that reference the
         quarter ended March 31, 2019 in lieu of September 30, 2017.
       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 Frank Knapp, Staff Accountant at (202) 551-3805 or
Kathleen Collins,
Accounting Branch Chief at (202) 551-3499 with any questions.



                                                              Sincerely,
FirstName LastNameGreg Halpern
                                                              Division of
Corporation Finance
Comapany NameMax Sound Corporation
                                                              Office of
Information Technologies
August 5, 2019 Page 2                                         and Services
FirstName LastName