December 24, 2019

Michael J. Roper
Chief Executive Officer
Muscle Maker, Inc.
308 East Renfo Street, Suite 101
Burleson, Texas 76028

       Re: Muscle Maker, Inc.
           Amendment No. 1 to Registration Statement on Form S-1
           Filed December 16, 2019
           File No. 333-235283

Dear Mr. Roper:

      We have reviewed your amended registration statement 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our December 9,
2019 letter.

Amendment No. 1 to Registration Statement on Form S-1

General

1.     With respect to your resale prospectus, please revise to address the
following:

           Please ensure that your principal stockholder table and selling
stockholder tables are
           consistent. For example, it appears that Messrs. Southall and Mohan
are selling
           stockholders, however, the selling stockholder table does not
reflect the amount of
           shares it appears they will beneficially own after the resale
offering, based upon the
           number of shares reflected in the principal stockholder table.
           Explain how you have arrived at the number of shares you are
registering for resale,
           as the amounts discussed under "Shares registered for resale"
discussing the
           December 5, 2019 conversions total an amount less than the 6,313,886
shares you are
 Michael J. Roper
Muscle Maker, Inc.
December 24, 2019
Page 2
              registering.

        Please contact Scott Anderegg at 202-551-3342 or Mara Ransom at
202-551-3264 with
any other questions.



FirstName LastNameMichael J. Roper                      Sincerely,
Comapany NameMuscle Maker, Inc.
                                                        Division of Corporation
Finance
December 24, 2019 Page 2                                Office of Trade &
Services
FirstName LastName