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                            February 17, 2023

       Thomas Shannon
       Chairman and Chief Executive Officer
       Bowlero Corp.
       7313 Bell Creek Road
       Mechanicsville, Virginia 23111

                                                        Re: Bowlero Corp.
                                                            Form 10-K for
Fiscal Year Ended July 3, 2022
                                                            Form 8-K filed
November 16, 2022
                                                            File No. 001-40142

       Dear Thomas Shannon:

              We have reviewed your filings 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 8-K filed November 16, 2022

       Exhibit 99. 1 Press Release, page 1

   1.                                                   In your press release
you disclose the Non-GAAP measure " Adjusted EBITDA Margin".
                                                        Please revise to
disclose the most comparable GAAP measure "Net Loss Margin" with
                                                        equal or greater
prominence in any future press releases. Refer to the guidance in Item
                                                        10(e)(1)(i)A of
Regulation S-K, Regulation G and Question 102.10 of the Compliance and
                                                        Disclosure
Interpretations Regarding Non-GAAP Measures.
   2.                                                   In your press release,
you disclose the Non-GAAP Measure "Center EBITDA". Please
                                                        revise to disclose why
you believe this measure is meaningful to potential investors as
                                                        well as the additional
purposes, if any, that this measure is used by management. Refer to
                                                        the guidance in Item
10(e)(1)(i)(C) and (D) of Regulation S-K. Also, as it does not appear
                                                        that you have adjusted
for all SG&A expenses incurred during the periods in arriving at
                                                        this measure, please
explain in further detail how you determined the amounts of the
                                                        adjustments made for
SG&A expenses in arriving at this Non-GAAP measure.
 Thomas Shannon
Bowlero Corp.
February 17, 2023
Page 2

        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 Linda Cvrkel at (202) 551-3813 or Angela Lumley at (202)
551-3398
with any questions.



FirstName LastNameThomas Shannon                          Sincerely,
Comapany NameBowlero Corp.
                                                          Division of
Corporation Finance
February 17, 2023 Page 2                                  Office of Trade &
Services
FirstName LastName