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                               December 9, 2020

       Allen Wolff
       Chief Executive Officer
       NTN Buzztime, Inc.
       6965 El Camino Real, Suite 105-Box 517
       Carlsbad, CA 92009

                                                        Re: NTN Buzztime, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-4
                                                            Filed November 25,
2020
                                                            File No. 333-249249

       Dear Mr. Wolff:

              We have reviewed your 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.

       Amendment No. 1 to Registration Statement on Form S-4

       Prospectus Summary, page 7

   1.                                                   We note your response
to prior comment 3 and your updated disclosure in the Risk
                                                        Factors and Brooklyn
Business sections. Please also update your Prospectus Summary
                                                        section, where
appropriate, to explain that there is no guarantee that the FDA will review
                                                        IRX-2 or Brooklyn   s
other product candidates on an expedited timeline and that fast track
                                                        and orphan drug
designations are not a guarantee of eventual FDA approval.
       NYSE American Listing, page 15

   2.                                                   Please revise here and
on the cover page to indicate when you will file the initial listing
                                                        application and whether
NYSE American's determination will be known at the time that
                                                        shareholders are asked
to vote on the merger agreement.
 Allen Wolff
FirstName LastNameAllen  Wolff
NTN Buzztime,   Inc.
Comapany9,
December  NameNTN
             2020    Buzztime, Inc.
December
Page 2    9, 2020 Page 2
FirstName LastName
Opinion of NTN Financial Advisor
Comparable Public Company Analysis, page 112

3.       We note your response to prior comment 13; however, it appears that
you have revised
         the Comparable M&A Transactions Analysis and not revised the
Comparable Public
         Company Analysis. Accordingly, please revise your Comparable Public
Company
         Analysis disclosure to explain why Newbridge selected a characteristic
(i.e., "past Phase II
         of U.S. FDA trials") that does not appear to apply to Brooklyn or
possibly to the four
         comparable public companies listed in the table at the top of page
113.
IRX-2 Technology, page 172

4.       We note your response to prior comment 20. Please revise your
disclosure on page 172 to
         identify the data or study which suggests IRX-2 reduces the immune
suppression that is
         often seen in the cancer tumor microenvironment. To the extent that
your statement is
         based on the INSPIRE Study, please further revise to clarify, if true,
that this study did not
         involve a statistically significant sample size and identify, as
applicable, any other
         material limitations or factors that make the matter speculative or
add uncertainty.
Historical Background of the Inspire Study, page 174

5.       We note your statement that pronounced lymphocytic infiltration was
seen in some tumors
         in the Phase 2a clinical trial of IRX-2, which could be linked to
enhanced immune
         response. Please revise your disclosure to state how many patients had
lymphocytic
         infiltration and to explain briefly how lymphocytic infiltration is
linked to an enhanced
         immune response.
6.       We note your statement that some tumors showed decrease in overall
size in the Phase 2a
         clinical trial of IRX-2 while some tumors increased in size. Please
revise your disclosure
         to indicate how many patients experienced tumor shrinkage and how many
patients
         experienced tumor growth. We further note your statement that the
tumor
         measurement findings in the trial "support the safety of the
neoadjuvant regimen." Safety
         is a determination that is solely within the purview of the FDA or
similar foreign
         regulators. Please revise this statement to remove the claim that your
product candidate
         may be found to be safe.
Brief Descriptions of Investigator Sponsored Studies, page 176

7.       We note your response to prior comment 22 and updated disclosure.
Please revise your
         disclosure to include the primary and secondary endpoints of each
trial, rather than
         referring readers to the clinicaltrials.gov website.
8.       We note your response to prior comment 23 and your revised disclosure
indicating that
         Phase 1 trials test both safety and efficacy. Clarify, if true, that
the purpose of Phase 1
         trials it to evaluate the treatment   s safety, determine a safe
dosage range, and identify side
         effects and that it is not designed or powered to assess efficacy.
 Allen Wolff
FirstName LastNameAllen  Wolff
NTN Buzztime,   Inc.
Comapany9,
December  NameNTN
             2020    Buzztime, Inc.
December
Page 3    9, 2020 Page 3
FirstName LastName
License and Royalty Agreements, page 177

9.       We note your response to prior comment 17 and your updated disclosure
in the Brooklyn
         Business section describing Brooklyn's license and royalty agreements.
Please revise your
         description of each agreement, as applicable, to disclose:

                To the extent Brooklyn has any continuing obligations
(including milestone
              payments) pursuant to each agreement beyond the royalty payments,
please describe
              these obligations;
                The duration and termination provisions for each agreement;
                The royalty term and any royalty term expiration provisions;

         With reference to the disclosure on please F-74, please revise your
description of the USF
         License Agreement to indicate whether any payments are owed in
addition to the
         $150,000 paid on August 13, 2020.
Brooklyn Management   s Discussion and Analysis of Financial Conditions and
Results of
Operations
Royalties on Product Sales, page 194

10.      We note your response to prior comment 26. Please update the
"Royalties on Product
         Sales" subsection to include a cross-reference to the location in the
Brooklyn Business
         section where these agreements are described.
Brooklyn ImmunoTherapeutics LLC Financial Statements
Note 4. Business Combination, page F-56

11.      We note your response to prior comment 30. Please revise the filing to
add a qualitative
         description of the factors that make up the goodwill recognized in
this business
         combination in accordance with ASC 805-30-50-1(a).
Note 11. Commitments and Contingencies
Royalty Agreements, page F-59

12.      Please reconcile the disclosure of the royalty rate owed to certain
noteholders and
         shareholders of IRX in this note and on page F-75 (7%) with that
provided on page F-73
         (13%). Also, we do not see where you have disclosed in this note and
on page F-75, the
         May 1, 2012 royalty agreement with a 1% royalty rate that you disclose
on page 177.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 Allen Wolff
NTN Buzztime, Inc.
December 9, 2020
Page 4

       You may contact Li Xiao at 202-551-4391 or Kate Tillan at 202-551-3604
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Alan Campbell at 202-551-4224 or Joe McCann at 202-551-6262 with any other
questions.



                                                           Sincerely,
FirstName LastNameAllen Wolff
                                                           Division of
Corporation Finance
Comapany NameNTN Buzztime, Inc.
                                                           Office of Life
Sciences
December 9, 2020 Page 4
cc:       Edwin Astudillo
FirstName LastName