November 26, 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 & Forms 10-K/A for the Fiscal Year Ended December 31, 2018
           Filed March 29, 2019, November 1, 2019 and November 19, 2019
respectively
           Form 10-Q for the Quarter Ended September 30, 2019
           Filed November 19, 2019
           File No. 000-51886

Dear Mr. Halpern:

       We have reviewed your November 19, 2019 response to our comment letter
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-Q for the Quarterly Period Ended September 30, 2019

Independent Registered Public Accounting Firm

1.    This is to inform you that Anton & Chia received a cease and desist order
on September
      20, 2019 and have been denied the privilege of appearing or practicing
before the
      Commission as an accountant
(https://www.sec.gov/litigation/admin/2019/34-87033.pdf).
      We further note that the firm's license has expired in all applicable
states. As Anton
      & Chia is barred from practicing before the SEC, you may not include its
audit report in
      your filings with the Commission on or after September 20, 2019. Since
Anton & Chia
      audited a year that you are required to include in your filings with the
Commission, you
      should have a firm that is registered with the PCAOB re-audit that year.
Please file an
      Item 4.01 Form 8-K and include all the information required by that Item
within four
      business days of receipt of this letter. In providing the information
that Item 304 of
 Greg Halpern
Max Sound Corporation
November 26, 2019
Page 2
         Regulation S-K requires, please also indicate that the firms license
has expired and that
         the SEC has implemented a cease and desist order.
2.       Considering Anton & Chia is no longer licensed or able to practice
before the
         Commission, please tell us what accounting firm reviewed the financial
statements
         included in your September 30, 2019 Form, 10-Q. Refer to Rule 8-03 of
Regulation S-X.
      You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or
Kathleen Collins,
Accounting Branch Chief at (202) 551-3499 if you have any questions.



FirstName LastNameGreg Halpern                                 Sincerely,
Comapany NameMax Sound Corporation
                                                               Division of
Corporation Finance
November 26, 2019 Page 2                                       Office of
Technology
FirstName LastName