United States securities and exchange commission logo

                             December 7, 2020

       Hilton Schlosberg
       President & Chief Financial Officer
       Monster Beverage Corp.
       1 Monster Way
       Corona, CA 92879

                                                        Re: Monster Beverage
                                                            Form 10-K for the
Year Ended December 31, 2019
                                                            Filed February 28,
                                                            File No. 001-18761

       Dear Mr. Schlosberg:

               We have reviewed your October 2, 2020 response to our comment
letter and have the
       following comment. In our comment, we may ask you to provide us with
information so we may
       better understand your disclosure.

              Please respond to this comment 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
       comment applies to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to this comment, we may have
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       September 21, 2020 letter.

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

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Non-GAAP Financial Measures, page 48

   1.                                                   We have carefully
considered your response to prior comment 1 and your revised
                                                        disclosures that
gross sales    represent the recognition of deferred revenue and amounts
                                                        invoiced to customers,
net of cash discounts and returns. Based on this clarification, it
                                                        appears that    gross
sales    is more akin to a billings-type metric. Accordingly, please
                                                        revise the title of
this metric so as not to imply that it represents GAAP sales or revenue
                                                        and comply with the
metrics guidance set forth in SEC Release No. 33-10751. Please also
                                                        clarify for us how the
amount of deferred revenue included in Gross Sales is determined.
                                                        In your response,
please include your proposed revisions, including your discussion of this
                                                        metric in MD&A.
 Hilton Schlosberg
Monster Beverage Corp.
December 7, 2020
Page 2

       You may contact Dale Welcome at 202-551-3865 or Anne McConnell at
202-551-3709 if
you have questions.

FirstName LastNameHilton Schlosberg                   Sincerely,
Comapany NameMonster Beverage Corp.
                                                      Division of Corporation
December 7, 2020 Page 2                               Office of Manufacturing
FirstName LastName