SecProbe.io

Mail Stop 4561
June 4, 2008
  Via U.S. Mail and Facsimile 414.905.2879

 Mr. Douglas A. Neis Chief Financial Officer and Treasurer The Marcus Corporation  100 East Wisconsin Avenue Suite 1900 Milwaukee, WI  53202-4125

Re: The Marcus Corporation
Form 10-K for Fiscal Ye ar Ended May 31, 2007
  Filed August 14, 2007   Definitive 14A
Filed September 12, 2007
File No. 001-12609

Dear Mr. Neis:

We have reviewed your response letter dated May 30, 2008 and have the
following additional comments.  If you disagr ee with our comments, we will consider
your explanation as to why our comments are not applicable.  Pleas e be as detailed as
necessary in your explanation.   After reviewing this informa tion, we may raise additional
comments.
   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our  comments or on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Douglas A. Neis
The Marcus Corporation June 4, 2008 Page 2  Form 10-K for the fiscal year ended May 31, 2007

 General

1. We note general counsel’s affirmation re garding the company’s awareness of its
obligations under the Secu rities Act of 1933 and the Exchange Act of 1934 and
the representations which followed.  Please provide to us the same representations
from the company, signed by an appropriate officer of the company.

Item 7. Management’s Discussion and Analysis
 Hotels and Resorts, page 25

2. We note your response to our comment number four; however, we continue to
believe that you should disclose in your  future filings the actual amounts of
RevPAR, occupancy, and average daily room  rates for the periods reported.  This
disclosure appears to be standard in th e hotel industry so it is not clear why you
believe disclosure by your company woul d cause competitive harm.  We also note
that this information is reported by Smith  Travel Research so it appears that you
have previously released the information and the information appears to be
relevant to analysts and investors.

Item 8. Financial Statements and Supplementary Data

Consolidated Statements of Earnings, Page 39
3. We have reviewed your response to comm ent number six and your support for the
significance of the line item to the company.  Please tell us whether current and
future revenue streams expected from your  unconsolidated joint ventures are the
same streams that the company currently en joys.  For those revenue streams of the
unconsolidated joint ventures that are not  the same as those currently enjoyed by
the company, please provide additional information supporting your compliance with Rule 5-03(b) of regulation S-X.

Definitive 14A for the fiscal year ended May 31, 2007

 Compensation Discussion and Analysis

 Role of Our Compensation Committee, page 11

4. We note your response to our comment number eight that the compensation
committee did not receive or review the identities of the companies used by Watson Wyatt in preparing compensation data for the committee.  Please tell us and revise future filings to describe in more detail th e data that the compensation

Douglas A. Neis
The Marcus Corporation June 4, 2008 Page 3
committee receives from Watson Wyatt and disclose that the compensation committee does not receive or consider the identities of the companies for which
it has received compensation data.  Clar ify whether Watson Wyatt provides data
on a company-by-company basis or if it provi des average data w ithin each market
sector.  Please note that if you are benchmarking compensation to certain
companies, you must identif y all of the companies in your future filings.

Cash Bonuses, page 12

5. We note your response to our comment no. 11, which addresses disclosure of
targets for future years.  Please confir m that you will disclose your 2008 Adjusted
EBITDA target in connection with your discussion of 2008 compensation
amounts in the 2009 proxy statement.

*     *     *

As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.   Please submit a response letter on EDGAR
that keys your response to our comments and provide any requested information.
Detailed cover letters greatly facilitate our review.  Please understa nd that we may have
additional comments after reviewin g your response to our comments.

You may contact Mark Rakip, Sta ff Accountant, at 202.551.3573 or the
undersigned at 202.551.3629 if you have questions  regarding comments on the financial
statements and related matters.  Please contact Kristina Aberg, Staff Attorney, at 202.551.3404 or Karen Garnett, Assistant Di rector, at 202.551.3785 with any other
questions.          S i n c e r e l y ,
Kevin Woody   Accounting Branch Chief