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August 8, 2022
Gunther Plosch
Chief Financial Officer
The Wendy's Company
One Dave Thomas Blvd.
Dublin, OH 43017
Re:The Wendy's Company
Form 10-K for the Fiscal Year Ended January 2, 2022
Filed March 1, 2022
File No. 001-02207
Dear Mr. Plosch:
            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 January 2, 2022
Management's Discussion and Analysis of Financial Conditions and Results of Operations
Results of Operations, page 38
1.We note your presentation of Restaurant Margin.  Please expand your disclosure to
explain the limitations on the usefulness of company-operated restaurant margins to
emphasize that it excludes costs that are necessary to support the operations of your
restaurants. This comment also applies to your Form 10-Q and Item 2.02 Form 8-K for the
fiscal quarter ended April 3, 2022.
2.Your results of operations year-to-year comparison for revenue identifies multiple factors
for material changes in each of the revenue categories without quantifying the impact of
each.  Please quantify the change for each of the factors that you cite.  Refer to Item
303(b) of Regulation S-K.
            We remind you that the company and its management are responsible for the accuracy

 FirstName LastNameGunther Plosch
 Comapany NameThe Wendy's Company
 August 8, 2022 Page 2
 FirstName LastName
Gunther Plosch
The Wendy's Company
August 8, 2022
Page 2
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Nasreen Mohammed at 202-551-3773 or Joel Parker at 202-551-3651 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services