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,
Inc.
Form 10-K for the
Fiscal Year Ended December 29, 2019
Filed February 20,
2020
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
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-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)
551-3769
with any questions.
FirstName LastNameStuart Levy Sincerely,
Comapany NameDomino s Pizza, Inc.
Division of
Corporation Finance
October 9, 2020 Page 2 Office of Trade &
Services
FirstName LastName