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                                 January 7, 2021

       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. 2 to
Registration Statement on Form S-4
                                                            Filed December 22,
2020
                                                            File No. 333-249249

       Dear Mr. Wolff:

             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
December 9, 2020 letter.

       Amendment No. 2 to Registration Statement on Form S-4

       IRX-2 Technology, page 171

   1.                                                   Please also revise your
disclosure to clearly explain the difference between the clinical
                                                        trials described in the
first bullet point and in the third bullet point. If the data discussed in
                                                        the third bullet point
comes from your ongoing INSPIRE Phase 2b clinical trial, please
                                                        revise to present a
detailed summary of this data in the prospectus. In your revisions,
                                                        please include how
"significant increases" in T-cell infiltration and "significant immune
                                                        responses" in three
quarters of patients were quantified and measured.
       The INSPIRE Study, page 173

   2.                                                   We note your response
to prior comment 5 and re-issue. Your current disclosure states
 Allen Wolff
NTN Buzztime, Inc.
January 7, 2021
Page 2
      that pronounced lymphocytic infiltration was "seen in some tumors."
Please revise your
      disclosure to state how many patients experienced pronounced lymphocytic
infiltration
      following the dosing of IRX-2. Alternatively, please tell us where this
disclosure appears.
License and Royalty Agreements, page 176

3.    We note your response to prior comment 9 and your updated disclosure and
re-issue in
      part. Please update your description of the USF License Agreement and the
other license
      and royalty agreements to discuss the expiration date and termination
provisions in each
      agreement.
4.    Please update your discussion of the Novellus option agreements to
disclose:

             Whether Brooklyn will have any development obligations with
respect to the licensed
           technology if it exercises the license option;
             The royalty rate, or a range no greater than 10 percentage points
per tier, if Brooklyn
           exercises the license option;
             The aggregate amount of milestones payable if Brooklyn exercises
the license option;
           and
             (i) the expiration date of the license and (ii) a discussion of
the license termination
           provisions, in each case, if Brooklyn exercises the license option.
Management Prior to and Following the Merger and Asset Sale
Executive Officers and Directors of the Combined Company Following the Merger,
page 221

5.    We note your disclosure that Dr. Stergiopoulos is currently and will
continue to be the
      President and Chief Executive Officer of A2A Pharmaceuticals. Please
revise your
      disclosure to clarify how much time, including the number of hours per
week, that Dr.
      Stergiopoulos will devote to his duties with Brooklyn. To the extent that
Dr. Stergiopoulos
      is expected to devote less than 100% of his time to Brooklyn, please
disclose this fact in
      the Summary. Please also revise the disclosure on page 232 to describe
the consulting
      services that Dr. Stergiopoulos will provide and file the agreement as an
exhibit to the
      registration statement.
       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
January 7, 2021 Page 2
cc:       Edwin Astudillo
FirstName LastName