United States securities and exchange commission logo May 7, 2021 Michael Roper Chief Executive Officer Muscle Maker, Inc. 308 East Renfro Street, Suite 101 Burleson, Texas 76028 Re: Muscle Maker, Inc. Registration Statement on Form S-3 Filed April 30, 2021 File No. 333-255700 Dear Mr. Roper: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Daniel Morris at 202-551-3314 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Stephen Fleming