DPZDomino's

You present the non-GAAP measure of EBITDA per store in your Annual Report to Security Holders. Please revise to include the disclosures required by Item 100(a) of Regulation G.

The Company supplementally advises the Staff that the estimated EBITDA per U.S. franchise store is a statistical measure that is not derived from any financial data contained in the Company’s financial statements. As a result, in accordance with Rule 101(a)(2) of Regulation G, the referenced metric is not within the definition of non-GAAP financial measures because it is not a numerical measure of the Company’s historical or future financial performance, financial position or cash flows and, further, it is a statistical measure calculated using exclusively operating measures or other measures

Rest of the answer

(namely an internal Company estimate of estimated U.S. franchisee EBITDA based on unaudited results self-reported by U.S. franchise owners) that are not non-GAAP financial measures. The Company respectfully advises the Staff that, as noted above, estimated EBITDA per U.S. franchise store is not a numerical measure of the Company’s (registrant’s) historical or future financial performance, financial position or cash flows, but is rather an estimate of the average profitability of the Company’s U.S. franchise stores, an operating measure that reflects the general health of the Company’s U.S. franchise business.

In response to the Staff’s comment, in all future letters to shareholders or other public disclosures that contain this statistical measure, the Company will include additional detail clarifying the fact that this statistical measure is an internal Company estimate based on unaudited results self-reported by U.S. franchise owners.

I hope that the foregoing has been responsive to your comments. If you should have any questions about this letter or require any further information, please call me at (734)-930-3030.

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