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Mr. David R. Humphrey
Accounting Branch Chief
Division of Corporation Finance
United States Securities and Exchange Commission
Washington, DC 20549

March 21, 2005

Re:   Ark Restaurants Corp.
      Form 10-K for the year ended October 2, 2004
      File No. 0-14030

Dear Mr. Humphrey:

         This letter is in response to your comment letter dated March 9, 2005
("Comment Letter") dealing with the annual report on Form 10-K of Ark
Restaurants Corp. (the "Company") for the year ended October 2, 2004. The
paragraphs numbered below are keyed to the numbered paragraphs in the Comment
Letter.

1. Comment 1. In future filings, the suggested additional details will be
provided.

2. Comment 2. In future filings, the suggested caption will be included.

3. Comment 3. The Company has raised menu items in some locations in the past
year as was disclosed, however, it is impractical to track these items
separately for financial reporting purposes because no two menus in any of the
Company's restaurants or fast food outlets are identical. Also, price increases
did not affect all menu items in the locations where prices were raised. In
future filings, the Company will expand the disclosure relating to menu price
increases when appropriate.

4. Comment 4. In future filings, the suggested narrative will be provided.

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5. Comment 5. In future filings, this revision will be reflected along with any
other amounts similarly affected.

6. Comment 6. The Company no longer has a credit line with Bank Leumi USA as the
facility matured on March 12, 2005. The Company does not currently plan to enter
into another credit facility and expects required cash to be provided by
operations. If cash is required for additional restaurant facilities the Company
will look to outside investors or landlords for the funds.

7. Comment 7. In future filings, the Company will expand the footnote disclosure
regarding the testing of goodwill impairment to specifically indicate that the
impairment analysis is performed on a single entity basis.

8. Comment 8. The landlord receivables relate to our restaurants at the Venetian
in Las Vegas. The Company expects to fully utilize these receivables to reduce
contingent rent payments over the life of leases that run to 2019. If no
contingent rent payments were due this would indicate that the restaurants in
question were not meeting the Company's expectations. If this were to occur, the
possibility would exist for the Company to negotiate with the landlord to return
the leases for these restaurant locations. As part of this negotiation, the
receivables may have to be discounted.

9. Comment 9. The Company has reviewed SFAS 57 "Related Party Disclosures" and
the relationship that exists between the Florida operations and the Company. The
Florida operations do not fall within the definition of a related party detailed
in paragraph 1 of SFAS 57.

         We trust that the foregoing is responsive to the Comment Letter. Please
contact the undersigned if there is any further information you require of if
you have any additional comments.

Sincerely yours,

Ark Restaurants Corp.

By: /s/ Robert J. Stewart
    ---------------------------
        Robert J. Stewart
        Chief Financial Officer

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