August 31, 2006

Via U.S. Mail and Facsimile

David A. Brandon
Chief Executive Officer
Domino`s Pizza, Inc.
30 Frank Lloyd Wright Drive
Ann Arbor, Michigan 48106




RE:		Domino`s Pizza, Inc.
		Form 10-K for the fiscal year ended January 1, 2006
		File No. 333-114442

Dear Mr. Brandon:

      We have limited our review of your Form 10-K for the fiscal
year ended January 1, 2006, to disclosures relating to your
contacts
with countries that have been identified as state sponsors of
terrorism.  Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues.  At this juncture, we are asking you to provide us with
supplemental information, so that we may better understand your
disclosure.  Please be as detailed as necessary in your response.
After reviewing this information, we may raise additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


General -

1. It appears from information available in the public domain that
you may have franchise agreement(s) covering Iran and Syria, and
may
have franchise operations in those countries. Your 10-K does not
include any information regarding contacts with those countries.
Iran and Syria are identified by the U.S. State Department as
state
sponsors of terrorism, and are subject to U.S. economic sanctions.
Please describe for us the extent and nature of your past,
current,
and anticipated contacts with those countries, if any, whether
through franchisees, franchise agreements, subsidiaries,
affiliates
or other direct or indirect arrangements.

2. Discuss for us the materiality to you of your contacts with
Iran
and Syria, individually and in the aggregate, and whether those
contacts, individually or in the aggregate, constitute a material
investment risk for your security holders.  Please address
materiality in quantitative terms, including the dollar amounts of
any associated assets and liabilities, and revenues.  Please also
address materiality in terms of qualitative factors that a
reasonable
investor would deem important in making an investment decision,
including the potential impact of corporate activities upon a
company`s reputation and share value.

We note, for example, that Arizona and Louisiana have adopted
legislation that requires their state retirement systems to
prepare
reports regarding state pension fund assets invested in, and/or
permits divestment of state pension fund assets from, companies
that
do business with U.S.-designated state sponsors of terrorism.  The
Pennsylvania legislature has adopted a resolution directing its
Legislative Budget and Finance Committee to report annually to the
General Assembly regarding state funds invested in companies that
have ties to terrorist-sponsoring countries.  The Missouri
Investment
Trust has established an equity fund for the investment of certain
state-held monies that screens out stocks of companies that do
business with U.S.-designated state sponsors of terrorism.  Your
materiality analysis should address the potential impact of the
investor sentiment evidenced by such actions directed toward
companies that operate in Iran and Syria.


Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, please
provide,
in writing, a statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; and

the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.

								Sincerely,



								Cecilia D. Blye, Chief
								Office of Global Security
Risk



Chris H. Owings
David Mittelman
James Allegretto
Division of Corporation Finance

David A. Brandon
Domino's Pizza, Inc.
August 31, 2006
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE