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