United States securities and exchange commission logo

February 23, 2022

Eric Langan
Chief Executive Officer and President
RCI Hospitality Holdings, Inc.
10737 Cutten Road
Houston, TX 77066

Re: RCI Hospitality
Holdings, Inc.
Form 10-K for the
Fiscal Year Ended September 30, 2021
Filed December 14,
File No. 001-13992

Dear Mr. Langan:

We have completed our review of your filing. 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.


Division of Corporation Finance

Office of Trade & Services