July 9, 2019

Patrick Harkleroad
Chief Financial Officer
Chanticleer Holdings, Inc.
7621 Little Avenue, Suite 414
Charlotte, NC 28226

       Re: Chanticleer Holdings, Inc.
           Form 10-K for the Year Ended December 31, 2018
           Form 8-K furnished May 15, 2019
           File No. 001-35570

Dear Mr. Harkleroad:

       We have reviewed your filing 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, 2018

Item 1. Business
Restaurant Brands
Better Burgers Fast Casual, page 4

1.    We note your disclosure in the Business section of the Form 10-K that you
operate a
      system-wide total of 49 Better Burger restaurants, 5 Just Fresh
restaurants and 8 Hooters
      restaurants. Please reconcile these amounts with a statement by Patrick
Harkleroad in the
      fourth quarter 2018 earnings release call that you opened 70 stores in
2018.
Form 8-K furnished May 15, 2019

Ex 99.1, page 1

2.    We note that your non-GAAP measure, Restaurant EBITDA, is reconciled to
Adjusted
      EBITDA. In this regard, please revise to reconcile Restaurant EBITDA to
the most
 Patrick Harkleroad
Chanticleer Holdings, Inc.
July 9, 2019
Page 2
         directly comparable GAAP measure in accordance with Item100(a)(2) of
Regulation G,
         which we believe would be operating income/loss. In this regard, it
appears this non-
         GAAP measure is not indicative of overall company performance and
profitability in that
         this measure does not accrue directly to the benefit of shareholders
due to the nature of the
         costs (depreciation and amortization, general and administrative, and
preopening costs)
         excluded from the measure. The indicated reconciliation appears to be
more representative
         of the measure as a restaurant level contribution to your results,
rather than a
         reconciliation to net income which is an overall company measure.


        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 Claire Erlanger at
202-551-3301 with
any questions.



FirstName LastNamePatrick Harkleroad                           Sincerely,
Comapany NameChanticleer Holdings, Inc.
                                                               Division of
Corporation Finance
July 9, 2019 Page 2                                            Office of
Transportation and Leisure
FirstName LastName