SecProbe.io

CORRESP
1
filename1.htm

January
11, 2017

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549-3628

Mail
Stop 3720

Attention:
Larry Spirgel, Assistant Director

    Re:
    NTN
    Buzztime, Inc.

    Form
    10-K for fiscal year ended December 31, 2015

    Filed
    March 15, 2016

    File
    No. 001-11460

Dear
Mr. Spirgel:

NTN
Buzztime, Inc. (the “Company”), provides the following response to the letter of the staff (the “Staff”)
of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Commission”) dated
December 28, 2016 (the “Comment Letter”) relating to the above-referenced filing.

For
convenience, the numbered paragraphs below correspond to the numbered paragraphs of the Comment Letter and the text of the Staff’s
comments appear in italics below.

Item
1. Business Licensing, Trademarks, Copyrights and Patents, page 6

    1.
    We
    note the importance of your intellectual property to your business (e.g., disclosures to this effect in your Licensing, Trademarks,
    Copyrights and Patents section and in your risk factor on page 10). In future filings, please disclose the duration of all
    your material patents pursuant to Item 101(h)(4)(vii) of Regulation S-K.

Response:
In response to the Staff’s comment, the Company proposes to provide disclosure substantially similar to the disclosure below
in its Form 10-K for its fiscal year ended December 31, 2016:

Our
intellectual property assets, including patents, trademarks, and copyrights, are important to our business and, accordingly, we
actively seek to protect the proprietary technology that we consider important to our business. No single patent or copyright
is solely responsible for protecting our products.

We
keep confidential as trade secrets our technology, know-how and software. Some of the hardware we use in our operations is customized,
and all of it is purchased from outside vendors. We enter into agreements with third parties with whom we conduct business, which
contain provisions designed to protect our intellectual property and to limit access to, and disclosure of, our proprietary information.
We also enter into confidentiality and invention assignment agreements with our employees and contractors.

       1

We
believe the duration of our patents is adequate relative to the expected lives of our products. We consider the following United
States patents to be important to the protection of our products and service:

    Patent No.
    Description
    Expiration Date

    8,562,438
    System and method for television-based services
    4/21/2031

    8,562,442
    Interactive gaming via mobile playmaker
    6/3/2031

    8,790,186
    User-controlled entertainment system, apparatus and method
    2/6/2034

    8,898,075
    Electronic menu system and method
    9/11/2032

    9,044,681
    System and method for television-based services
    10/13/2033

    9,358,463
    Interactive gaming via mobile playmaker
    10/16/2033

    9,498,713
    User-controlled entertainment system, apparatus and method
    2/6/2034

We
have trademark protection for the names of our key proprietary programming, products, and services to the extent that we believe
trademark protection is appropriate. We are expanding our efforts to protect these investments. We consider the Buzztime, Playmaker,
Mobile Playmaker, BEOND Powered by Buzztime and PlayersPlus trademarks and our other related trademarks
to be valuable assets, and we seek to protect them through a variety of actions. Our content, branding, and some of our game titles,
such as Countdown, SIX, and Showdown are also protected by copyright and trademark law.

The
Company confirms that it will comply with the Staff’s comment in future filings by providing disclosure substantially similar
to the above when and as required and as such disclosure may be updated to reflect then accurate information.

2. Discuss
                                         whether the gaming content available on your devices is the result of internal development
                                         or licenses or acquired technology from third parties. If material, disclose the dollar
                                         amount for such licenses or technology.

Response:
In response to the Staff’s comment, the Company proposes to provide disclosure substantially similar to the disclosure below
in its Form 10-K for its fiscal year ended December 31, 2016.

A
majority of the gaming content available on our BEOND platform is internally developed. The balance is licensed from third parties.
We also license third party content for our pay-to-play and free-to-consumer arcade content. The amounts paid for such third party
licensed content was not material during either 2016 or 2015.

All
of the gaming content available on our Classic platform is internally developed.

The
Company confirms that it will comply with the Staff’s comment in future filings by providing disclosure substantially similar
to the above when and as required and as such disclosure may be updated to reflect then accurate information.

*        *        *

The
Company looks forward to working with the Staff toward resolving any concerns that the Staff may continue to have after evaluating
and taking into account the Company’s response in this letter. To this end, the Staff should feel free to call Sandra Gurrola,
the Company’s Vice President of Finance at 760.930.1168, or the Company’s outside securities counsel (Edwin Astudillo
at 619.318.9987 or Elizabeth Wilson at 858.847.2810) with any questions or if the Staff wishes to discuss any of the above.

    Sincerely,

    NTN
    Buzztime, Inc.

    /s/
    Ram Krishnan

    Ram
    Krishnan, CEO

    cc:
    Courtney
    Lindsay, Staff Attorney

    Edwin
    Astudillo, Esq.

    Elizabeth
    Wilson, Esq.

       2