United States securities and exchange commission logo

                              October 9, 2020

       Stuart Levy
       Executive Vice President, Chief Financial Officer
       Domino   s Pizza, Inc.
       30 Frank Lloyd Wright Drive
       Ann Arbor, MI 48105

                                                        Re: Domino   s Pizza,
                                                            Form 10-K for the
Fiscal Year Ended December 29, 2019
                                                            Filed February 20,
                                                            File No. 001-32242

       Dear Mr. Levy:

              We have reviewed your filing 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

              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-K for the Fiscal Year Ended December 29, 2019

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       2019 compared to 2018, page 33

   1.                                                   Please disclose the
business reasons for changes between periods in each segment's ASC
                                                        280 profit measure and
amounts in the Other column in Note 12 of your financial
                                                        statements. In
circumstances where there is more than one business reason for the change,
                                                        please quantify the
incremental impact of each individual business reason discussed on the
                                                        overall change in the
line item. Refer to Item 303(a)(3) of Regulation S-K and SEC
                                                        Release No. 33-8350.
       Financial Statements
       Note 12. Segment Information, page 71

   2.                                                   Please disclose in
greater detail the types of amounts included in the Other column of your
                                                        segment reconciliation
in arriving at the total for each segment profit measure. Please also
 Stuart Levy
Domino   s Pizza, Inc.
October 9, 2020
Page 2
         provide the segment disclosures discussed in ASC 280-10-50-22(e)
through (j) or tell us
         how you concluded they need not be provided.
3.       Please tell us your basis for presenting two measures of each
segment's profit (segment
         income and income from operations). Also, explain why the segment
income measure is
         permitted to be disclosed, when the income from operations measure
appears to be most
         consistent with GAAP. Refer to ASC 280-10-50-27 and 50-28.
        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 Keira Nakada at (202) 551-3659 or Rufus Decker at (202)
with any questions.

FirstName LastNameStuart Levy                                Sincerely,
Comapany NameDomino   s Pizza, Inc.
                                                             Division of
Corporation Finance
October 9, 2020 Page 2                                       Office of Trade &
FirstName LastName