March 24, 2020

Anthony Sirica
Chief Financial Officer
Ark Restaurants Corp.
85 Fifth Avenue
New York, NY 10003

       Re: Ark Restaurants Corp.
           Form 10-K for the Fiscal Year Ended September 28, 2019
           Filed December 17, 2019
           Form 8-K
           Furnished February 10, 2020
           File No. 001-09453

Dear Mr. Sirica:

       We have limited our review of your filings 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 September 28, 2019

Consolidated Statements of Income, page F-3

1.    We note your presentation of the sub-total "Restaurant Operating Income"
on the face of
      your statements of income and that this sub-total excludes certain
operating expenses for
      restaurant-related charges for impairments and asset write-offs. Please
tell us your basis
      for presenting this sub-total, which appears to be a non-GAAP financial
measure, on the
      face of the income statement, and for excluding restaurant-related
charges from it. Refer
      to Item 10(e)(1)(ii)(C) of Regulation S-K.
 Anthony Sirica
FirstName LastNameAnthony Sirica
Ark Restaurants Corp.
Comapany2020
March 24, NameArk Restaurants Corp.
Page 2
March 24, 2020 Page 2
FirstName LastName
Form 8-K furnished February 10, 2020

Exhibit 99.1
Ark Restaurants Announces Results for the First Quarter of 2020, page 1

2.       Please give prominence, here and in your periodic reports on Forms
10-K and 10-Q, to
         your GAAP measures of performance rather than your non-GAAP measures.
Refer to
         Item 10(e)(1)(i)(A) of Regulation S-K. Please also reconcile non-GAAP
measures of
         performance to the most directly comparable GAAP measure, net income.
Refer to
         Compliance and Disclosure Interpretations on Non-GAAP Financial
Measures, Question
         103.02.
       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 Robert Shapiro, Senior Staff Accountant, at 202-551-3273
or Lyn
Shenk, Accounting Branch Chief, at 202-551-3380 with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services