September 25, 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 issued comments on the above captioned filings on August 5, 2019. On
September 4,
2019, we issued a follow-up letter informing you that those comments remained
outstanding and
unresolved, and absent a substantive response, we would act consistent with our
obligations
under the federal securities laws.

         As you have not provided a substantive response, we are terminating
our review and will
take further steps as we deem appropriate. These steps include releasing
publicly, through the
agency's EDGAR system, all correspondence, including this letter, relating to
the review of your
filings, consistent with the staff s decision to publicly release comment and
response letters
relating to disclosure filings it has reviewed.

      Please contact Kathleen Collins, Accounting Branch Chief at 202-551-3499
or Craig
Wilson, Senior Assistant Chief Accountant at 202-551-3226 with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of
Information Technologies
                                                           and Services