September 4, 2018

Paul W. Mobley
Chief Financial Officer
Noble Roman's, Inc.
One Virginia Avenue, Suite 300
Indianapolis, Indiana 46204

       Re: Noble Roman's, Inc.
           Form 10-K for the Year Ended December 31, 2017
           Filed March 29, 2018
           File No. 000-11104

Dear Mr. Mobley:

       We have limited our review of your filing 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 Year Ended December 31, 2017

Financial Statements
Consolidated Balance Sheets, page 27

1.    Given the significance of your "other assets including long-term portion
of accounts
      receivable - net" to total assets, please provide us with the following:
        a breakdown of the significant items that comprise other assets, and
the amount of
          long-term accounts receivable included in the balance;
        the nature of the long-term accounts receivable including how it
originated and the
          reason it is considered long-term;
        provide further details on the amounts that were transferred to
long-term receivables
          and expand on the amounts related to former franchisees (page 16) and
why you
          consider them to be collectible; and
 Paul W. Mobley
Noble Roman's, Inc.
September 4, 2018
Page 2

             the details of the Heyser case including what amounts are
classified as long-term
             receivables related to the case and how you determine the
adjustments to the valuation
             of such receivables per the amounts recorded in your statement of
operations

Item 9A. Controls and Procedures
Management's Report on Internal Control Over Financial Reporting, page 45

2.       Please revise to include a statement identifying the framework used by
management to
         evaluate the effectiveness of internal control over financial
reporting (e.g., COSO
         framework 2013). Refer to Item 308(a)(2) of Regulation S-K.
       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 Heather Clark at 202-551-3624 or Jean Yu at 202-551-3305
with any
questions.



FirstName LastNamePaul W. Mobley                              Sincerely,
Comapany NameNoble Roman's, Inc.
                                                              Division of
Corporation Finance
September 4, 2018 Page 2                                      Office of
Transportation and Leisure
FirstName LastName