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December 30, 2020

Via EDGAR and E-mail

United States Securities and Exchange Commission

Divison of Corporation Finance

100 F Street, N.E.

Washington, D.C.  20549-3561

Attention: Paul Fischer, Staff Attorney

 Re: Monitronics International, Inc.

Form 10-K for the Fiscal Year Ended
December 31, 2019

Filed March 30, 2020

File No. 333-110025

Ladies and Gentlemen:

This letter contains the response of Monitronics
International, Inc. (“Monitronics”) to the comment (the “Comment”) of the staff (the “Staff”)
of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) contained in the
Staff’s letter dated December 14, 2020 (the “Comment Letter”), regarding the Form 10-K initially filed
by Monitronics with the Commission on March 30, 2020 (the “10-K”). Monitronics is respectfully submitting the
response below to the Comment in connection with its filing of the 10-K with the Commission on the date hereof.

For your convenience, the Staff’s
Comment, as set forth in the Comment Letter, has been repeated in its entirety in bold type below, with Monitronics’ response
set out immediately underneath the Comment.

Capitalized terms used, but not otherwise
defined, in this response letter are intended to have the respective meanings ascribed to such terms in the 10-K.

Form 10-K for the Fiscal Year Ended December 31,
2019

Item 7. Management's Discussion and Analysis of Financial
Condition and Results of Operations

Results of Operations (“MD&A”)

Year Ended December 31, 2019 Compared to Year Ended
December 21, 2018, page 32

 1. We note that you present non-GAAP combined financial information for the year ended December 31, 2019 which includes
results of operations for the predecessor and successor entities in the tables on pages 32 and 34 and in your discussion of
your operating results for this period. To the extent you wish to discuss your combined results of operations for these periods,
please revise to discuss and specifically quantify the impact that the adoption of fresh start accounting had on the successor
entities results of operations. Your disclosures in your quarterly reports on Form 10-Q and in your earnings releases furnished
in Form 8-Ks should be similarly revised.

Response: As discussed on our December 23, 2020
call with Ms. Linda Cvrkel and Mr. Blaise Rhodes, Monitronics respectfully submits that to the extent our results of
operations were impacted by the adoption of fresh start accounting and such impacts were readily quantifiable, the 10-K does include
such impacts in its discussion. However, Monitronics will endeavor to clarify such impacts in future filings and, where applicable,
provide additional quantitative analysis on MD&A disclosures addressing combined results of operations of predecessor and successor
periods for all future filings.

Please direct any questions that you have with respect to
the foregoing to the undersigned, at (972) 243-7443, or to David Miller, Latham & Watkins LLP, at (713) 546-7463.
Very truly yours,

    Monitronics International, Inc.

    By:
    /s/
    William E. Niles

    William E. Niles

    Chief Executive Officer

    cc:
    David J. Miller (Latham & Watkins LLP)