May 10, 2019

Tara Comonte
Chief Financial Officer
Shake Shack Inc.
225 Varick Street, Suite 301
New York, New York 10014

       Re: Shake Shack Inc.
           Form 10-K for the Fiscal Year Ended December 26, 2018
           Response dated April 30, 2019
           Form 10-Q for the Quarterly Period Ended March 27, 2019
           Filed May 6, 2019
           File No. 001-36823

Dear Ms. Comonte:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-Q for the Quarter Ended March 27, 2019

Statement of Cash Flows, page 7

1.    We note that your statement of cash flow for the three months ended March
27, 2019
      discloses $8,911 of amortization of operating lease assets. Please
explain to us the nature
      of this amount. In this regard, we note that the majority of your leases
are considered
      operating leases and would not have amortization expense recorded as part
of the lease
      accounting. Please advise.
Note 9. Leases, page 15

2.    We note your disclosure that tenant improvement allowances are recorded
as part of the
      lease liability on the Condensed Consolidated Balance Sheet and are
amortized on a
      straight-line basis over the lease term as a reduction to occupancy and
related expenses.
 Tara Comonte
Shake Shack Inc.
May 10, 2019
Page 2
         Please explain to us how your accounting for these lease incentives
complies with the
         guidance in ASC 842-20-30-5.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

      You may contact Beverly Singleton at (202) 551-3328 or Claire Erlanger at
(202) 551-
3301 with any questions.



FirstName LastNameTara Comonte                               Sincerely,
Comapany NameShake Shack Inc.
                                                             Division of
Corporation Finance
May 10, 2019 Page 2                                          Office of
Transportation and Leisure
FirstName LastName