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CORRESP
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Steven M.
Skolnick

Partner
One Lowenstein Drive

 Roseland,
New Jersey 07068

T:       (973) 597-2476

 F:       (973)
597-2477

 E:       sskolnick@lowenstein.com

August 11, 2023

Via Edgar

United States Securities and Exchange Commission

Division of Corporate Finance

Office of Trade & Services

Washington, DC 20549

    Attn:
    Aamira Chaudhry

    Doug Jones

    RE:
    Loop Media, Inc.

    Form 10-K for Fiscal Year Ended September 30,
    2022

    File No. 001-41508

Ladies and Gentlemen:

This letter sets forth the response of Loop Media, Inc.
(the “Company”) to the comments of the Staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) set forth in your letter dated June 6, 2023 (the “Comment
Letter”), which was in response to the Company’s letter to the Commission dated April 20,2023, with respect
to the Company’s Annual Report on Form 10-K for the year ended September 30, 2022, as filed with the SEC on December 20.
2022 (the “Annual Report”). As discussed with the Staff, neither the Company nor the undersigned received a
copy of the Comment Letter until July 20, 2023.

For your convenience, the Staff’s comment
is reprinted in bold below, followed by the Company’s response thereto.

The Company has authorized us to respond to the Comment Letter
as follows:

Item 1. Business

The Loop Platform

O&O Platform and OOH Locations, page 11

1. Here and numerous places elsewhere you use the acronym "DOOH." Please explain to us
                                and disclose what this means and how it relates to "OOH" locations.

    United States Securities and Exchange Commission
    August 11, 2023

Page 2

Response:

The Company acknowledges the Staff’s
comment and will include a definition of DOOH, as set forth below in its future filings with the Commission.

Digital out of home (“DOOH”)
is a form of media that is delivered digitally outside of the home on billboards, signage, displays, televisions, and other devices in
out of home (“OOH”) locations, including restaurants, retail shops, healthcare facilities, sports and entertainment
venues, and other public or non-residential spaces.

Management's Discussion and Analysis of Financial Condition and
Results of Operations

Consolidated Results of Operations

Gross Profit Margin, page 58

2. The second sentence under Partner Platform on page 5 of your response to comment 3 appears
                                to be useful information in further explaining the lower gross profit margin for the Partner Platform
                                disclosed on page 58. Please consider expanding your disclosure accordingly.

Response:

The Company acknowledges the Staff’s
comment and has included the additional disclosure set forth below in its Form 10-Q for its quarter ended June 30, 2023 filed
on August 9, 2023, and will include in future filings, with the Commission:

The Company curates the content and develops
the infrastructure required to create advertising inventory available for purchase in the Company’s O&O Platform (defined below)
business. For the Partner Platform (defined below) business, the infrastructure is developed by the owners or operators of the third-party
digital platforms, with the Company gaining access to such third-party platform for the delivery of advertising sales services by the
Company to such owners and operators. The Company may also deliver curated content on the Partner Platform, in instances where the owners
or operators of such platform do not provide their own content for streaming on the platform.

    United States Securities and Exchange Commission
    August 11, 2023

Page 3

Liquidity and Capital Resources

Cash Flows ...

Net Cash Flow From/Used In Operating Activities, page 61

3. Refer to your response to comment 2. Please note your present disclosure discussing items impacting
                                results reported on the accrual basis of accounting does not necessarily adequately explain how actual
                                cash for operating activities was impacted. Also note your present disclosure discussing aspects of your
                                cash flows from operations that breaks out amounts related to each component primarily focuses on noncash
                                items that do not affect cash. Refer to section IV.B.1 of Release No. 33-8350 and revise your disclosure
                                as appropriate.

Response:

The Company acknowledges the Staff’s
comment and has included the additional disclosure set forth below in its Form 10-Q for its quarter ended June 30, 2023 filed
on August 9, 2023, and will include in future filings, with the Commission:

Historically, the Company’s principal
sources of cash used in operating activities have included proceeds from the issuance of common stock, preferred stock and warrants and
proceeds from the issuance of debt.

The primary drivers in the reduction
in cash flows was due to reduced revenues resulting in lower receivables, coupled with the increased expenses related to SG&A resulting
in increased accounts payable. The overall net impact was lower cash flows period over period.

Although historically the Company has
reported significant recurring losses as well as negative cash flows used in operations, it intends to meet future cash requirements
and maintain operations by reducing overall operating expenses and continuing to focus on increasing the scope and size of the Loop Platform
and the scale and number of advertising revenue opportunities that may be available. In addition, the Company will continue to rely on
equity and debt capital raising activities, including sales of its common stock under its Sales Agreement (the Company’s “at-the-market”
facility, which has been disclosed in its filings with the Commission), to fund its operations.

    United States Securities and Exchange Commission
    August 11, 2023

Page 4

Notes to Consolidated Financial Statements

Note 2. Summary of Significant Accounting Policies

Revenue recognition,
page F-13

4. The chart on page 11 indicates your customers are (i) OOH locations for the O&O
                                Platform and (ii) third parties with their own distribution platform for the Partner Platform. On
                                page F-13 it appears your customers are advertising demand partners, advertising agencies and direct
                                advertisers and sponsors because you state amounts billed to these parties are recorded as revenues.
                                Please clarify for us who your customers are for each platform and for each customer type within each
                                platform how you (a) generate revenue from the customer and (b) incur the associated cost of
                                revenue and what these costs consist of. In connection with this, explain to us precisely what your performance
                                obligation is (i.e., the service you provide) for each customer type within each platform and how you
                                fulfil the performance obligation.

Response:

The Company acknowledges the Staff’s
comment and has included the additional disclosure set forth below in its Form 10-Q for its quarter ended June 30, 2023 filed
on August 9, 2023, and will include in future filings, with the Commission:

The Company offers
hand-curated music video content licensed from major and independent record labels, as well as non-music video content. The Company distributes
this content and advertising inventory to digital screens located in OOH locations primarily through (i) our owned and operated
platform (the “O&O Platform”) of Loop Media-designed “small-box” streaming Android media players
(or “Loop Players”) and legacy ScreenPlay computers and (ii) through screens on digital platforms owned
and operated by third parties (each a “Partner Platform” and collectively, the “Partner Platforms,”
and together with the O&O Platform, the “Loop Platform”).

The Company has two
primary constituents that are included in its customer base; the OOH locations it services and the advertisers who purchase advertising
inventory on the Loop Platform. The Company earns revenue from these customers primarily by selling advertising inventory on the Loop
Platform and by collecting subscription fees from our O&O Platform owners and operators that are streaming advertising-free content.

The O&O Platform

The Company delivers
content across its O&O Platform to the owners and operators of OOH locations who sign up for the Company’s media service. The
Company sells advertising impressions contained in the content streams to demand sources, including DSPs, SSPs and advertisers, who pay
the Company to fill those impressions and have their ads delivered into the OOH locations that utilize the Company’s services.
The Company also allows OOH locations on its O&O Platform to access the Company’s media service without advertisements by paying
a monthly subscription fee.

    United States Securities and Exchange Commission
    August 11, 2023

Page 5

From a business operations
standpoint, for the O&O Platform business, the Company views its customers as the owners and operators of the OOH locations that
use the Company’s content services to engage and entertain the customers that visit the OOH locations.

The Company’s
customer services team works with the owners and operators of OOH locations in our O&O Platform to ensure our customers are being
properly serviced and addressing any questions about the service, content, advertising performance and other matters.

From an accounting
standpoint, for the O&O Platform business, the Company’s customers are considered to be those persons that provide revenue
to the Company, which includes the owners and operators of the OOH locations that utilize a subscription-based service and the advertising
demand sources (including DSPs, SSPs and advertisers) that purchase our advertising inventory on the O&O Platform. From an accounting
standpoint, the owners and operators of the OOH locations utilizing a free advertising-based service on our O&O Platform are not
our customers. Instead, it is the advertising demand sources that are our customers because they are providing revenue to the Company
(by way of purchasing advertising inventory) for the streaming of content to those OOH locations utilizing an ad-free service.

The Company records
cost of revenue in the O&O Platform business certain costs and expenses associated with operating such business, including the cost
of content, streaming costs, and content hosting fees. The Company procures content from third parties though licensing fees or by purchasing
the content outright. The cost of content is the single largest component of the cost of revenue associated with the O&O Platform
business.

The Partner Platform

The Company provides
advertising demand services to third parties by selling ad impressions available on the Partner Platform to advertising demand sources
(including DSPs, SSPs and advertisers) who pay the Company to fill those impressions and have ads delivered across the Partner Platform.
If the advertising impressions are filled with advertisements the Company will fulfill its obligation and be paid as the publisher of
the advertisement. If advertising impressions are not purchased, the content will play without advertisements and no revenue will be
earned by the Company.

    United States Securities and Exchange Commission
    August 11, 2023

Page 6

From a business operations
standpoint, the Company’s customers are, for its Partner Platform services, the owners and operators of the third-party digital
platforms that utilize the Company’s content and advertising services, which enables such third parties to better monetize the
screens on their digital platforms. The Company may, in certain instances, also provide content across the Partner Platform.

The Company’s
customer services team works with the owners and operators of OOH locations in our O&O Platform and the owners and operators of third-party
digital platforms in our Partner Platforms to ensure our customers are being properly serviced and addressing any questions about the
service, content, advertising performance and other matters.

From an accounting
standpoint, for the Partner Platform business, the Company’s customers are the advertising demand sources (including DSPs, SSPs
and advertisers) because they are providing revenue to the Company (by way of purchasing advertising inventory) for the streaming of
content across the Partner Platform. The Partner Platform business operates a free ad-supported business model and has not subscription
fees.

The Company deducts
from the revenue it generates in the Partner Platform business certain costs and expenses associated with operating such business (including
streaming costs and content hosting) fees and then allocates the remaining revenue between the Company and the third-party digital platform
provider, based on pre-agreed negotiated percentages. The percentage of revenue it passes along to third-party digital platform providers
is recorded as cost of revenue, which is the Company’s single largest cost of revenue for the Partner Platform.

5. Please explain to us the difference between “advertising demand
                                            partners,” “advertisers” and "sponsors."

Response:

The Company acknowledges the Staff’s
comment and supplementally responds as follows:

Advertising

An advertiser is a corporation, organization,
government, or other entity that advertises its products and/or services or delivers a public service message to individuals or groups
of individuals.

    United States Securities and Exchange Commission
    August 11, 2023

Page 7

An advertiser may or may not engage
an advertising agency to determine how best to publish its advertisements, including digital publication through programmatic advertising.
Programmatic advertising is the automation of buying and selling advertisements electronically primarily through real-time bidding, with
ads placed in seconds on digital platforms.

Advertising agencies (and advertisers)
may engage advertising demand partners, in respect of their programmatic advertising needs, including demand-side platforms (“DSPs”)
and supply-side platforms (“SSPs”).

A DSP is a programmatic advertising
platform that advertisers, media buyers and agencies use to automate the process of buying ad inventory. A DSP can automate the decision-making
process for advertisers, including how much to bid for an ad in real-time. DSPs make the ad-buying process significantly faster and more
efficient and gives advertisers access to publishers of digital content and ads, like the Company.

An SSP is a platform that aggregates
publisher inventory for demand sources (including DSPs) to allow demand sources to evaluate and potentially purchase ad impressions.
SSPs give publishers the opportunity to auction ad inventory (ad impressions), fill the ad inventory and earn revenue from the publishing
of ads.

Sponsorship

A sponsor is a company or other entity
that pays the Company to promote the sponsor’s services or products in the Company’s OOH locations in our O&OM Platform
business. The sponsor’s promotion of its products and services would likely be targeted to a specific content channel, playlist
or company event that aligns with the sponsors brand or messaging.

6. You state you distribute your content and advertising inventory through
                                            your O&O Platform and Partner Platform. Please explain to us how the content and advertising
                                            inventory is yours and whether such was created or purchased by you. Explain to us what this
                                            content and adver