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                              August 26, 2020

       Paul F. Morina
       President and Chief Executive Officer
       Hometown International, Inc.
       25 E. Grant Street
       Woodstown, NJ 08098

                                                        Re: Hometown
International, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed July 7, 2020
                                                            Supplemental
Response
                                                            Filed July 31, 2020
                                                            File No. 333-238999

       Dear Mr. Morina:

             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 July
21, 2020 letter.

       Amendment No. 1 to Form S-1 filed July 7, 2020

       Prospectus Cover page, page i

   1.                                                   We note your disclosure
that the shares will be sold at the fixed price of $6.50 until such
                                                        time as your shares are
quoted in the over-the-counter market or listed on any national
                                                        securities exchange or
automated interdealer quotation system. Please revise to state that
                                                        the shares will be sold
at the fixed price of $6.50 until your shares are quoted on the over-
                                                        the-counter bulletin
board ("OTCBB"), or the OTCQX, or the OTCQB or listed on any
                                                        national securities
exchange or automated interdealer quotation system. Please also revise
                                                        your Plan of
Distribution disclosure accordingly.
 Paul F. Morina
Hometown International, Inc.
August 26, 2020
Page 2
Prospectus Summary, page 1

2.       Please acknowledge your auditor   s going concern opinion in the
summary, and your risk
         factors.
Private Placement, page 2

3.       We note your response to our prior comment. Please provide us your
analysis as to
         whether a subsequent change of control, following Mr. Coker's
disposition of his shares
         and the April private placement, has occurred. In this regard, we note
the following:
             according to your disclosure, the April private placement placed
substantial
             restrictions upon your operations, management and Board of
Directors;
             your beneficial ownership table suggests that Michael Tyldeseley
and
             Ibrahima Thiam, and affiliated entities, currently control you. If
true, please revise
             your beneficial ownership table to reflect their aggregate, even
if indirect,
             ownership.
4.       We note here your statement that you will use the proceeds of the
private placement,
         $2,500,000, to explore and evaluate potential merger candidates. We
also note your
         discussion on page 12 that you will investigate potential business
combinations and you
         have included related risk factors. Given that your deli business is
closed because of
         Covid-19 and you intend to explore and evaluate potential merger
candidates, please
         revise your disclosure throughout the prospectus to clarify, if true,
that your business is to
         find and merge with "entities having established operating histories."
In this regard,
         provide us with your analysis as to why you should not be considered a
shell company,
         consistent with Rule 405 of Regulation C.
5.       Please revise your disclosure to identify the three selling
shareholders who purchased
         shares in the private placement. You disclose that they are some of
the selling
         stockholders in this offering, however, the number of selling
stockholders listed on page
         30 far exceeds the three you say purchased 2,500,000 of the 2,783,637
shares you are
         registering for resale.
Risk Factors, page 4

6.       We note your disclosure, "Our common stock offered in this prospectus
is quoted on the
         OTC Pink under the symbol 'HWIN'." Please include a risk factor
describing any related
         risks specific to the Pink Market.
7.     Please revise to include a risk factor that acknowledges the volatility
of the price of the
       common stock you are offering for resale. In doing so, please
acknowledge your most
FirstName LastNamePaul F. Morina
       recent quotation price on the Pink Market, the price at which you are
offering shares in
Comapany    NameHometown
       this registration       International,
                         statement, the price Inc.
                                              at which you have sold shares in
recent private
Augustplacements    and 2repurchased shares and the exercise price of your
various warrants.
        26, 2020 Page
FirstName LastName
 Paul F. Morina
FirstName
HometownLastNamePaul        F. Morina
            International, Inc.
Comapany
August  26, NameHometown
            2020              International, Inc.
August
Page 3 26, 2020 Page 3
FirstName LastName
Our Business, page 10

8.       Please elaborate upon the arrangements you have entered into with
Tryon Capital
         Ventures and VCH Limited for $15,000 and $25,000 per month,
respectively, to explain
         exactly what services each consultant will be providing you.
Considering your lack of
         revenue, please revise your liquidity disclosure to explain how you
intend to finance these
         obligations. If the use of proceeds from your recent private placement
will be used for
         these obligations, please state as much.
Liquidity and Capital Resources, page 18

9.       We note your auditors have issued a going concern opinion. Please
disclose your rate of
         negative cash flow per month and management   s belief as to the
period of time that
         available cash can sustain your current operations. Please refer to
Item 303(a) of
         Regulation S-K.
10.      We note your disclosure that you fully repaid the notes payable from
related party totaling
         $285,126 along with accrued interest on April 24, 2020. If the loans
were repaid using
         proceeds from the private placement, please state as much. Please also
revise to disclose
         the identity of the related party and disclose the remaining balance
of amounts owed to
         related parties, if any.
Selling Shareholders, page 29

11.      For each selling shareholder, please describe the transaction in which
they acquired the
         shares that they are offering for resale.
Consolidated Financial Statements, page F-1

12.      Please revise to update your financial statements, and accompanying
Management's
         Discussion and Analysis and auditor's consent, to reflect the most
recent quarter for which
         you have recently filed a quarterly report on Form 10-Q.
General

13.      Please provide the disclosure required by Item 5 of Form S-1 and
Regulation 505 of
         Regulation S-K concerning how you determined the offering price.
       You may contact Scott Anderegg at 202-551-3342 or Mara Ransom at
202-551-3264
with any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Trade &
Services