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Letter to the Securities and Exhange Commission

 March 3, 2005

 Correspondence not for dissemination to the public, filed on EDGAR

 Ms. Linda Cvrkel

 Branch Chief

 Securities and Exchange Commission

 Washington, D. C. 20549

Re:
Frisch’s Restaurants, Inc.

 Commission File Number
001-07323

 Dear Ms. Cvrkel:

 As indicated in our February 25, 2005 initial response, we are hereby responding further to
the issue raised in Item #6 of your February 14, 2005 letter.

 Notes to the
Financial Statements

 Note C – Leased Property

 Comment 6 –The Company has performed a comprehensive review of all of its operating leases and consulted with its independent auditors to assess the impact of
conforming with paragraph 15 of SFAS No. 13, as amended. As indicated in our February 25, 2005 letter, the Company erred by not accounting for escalating rental payments on a straight-line basis over the terms of the applicable leases. Further, we
have now determined that the Company also incorrectly interpreted the definition of the rent holidays that precede the opening date of its leased restaurants and therefore failed to record rent expense during the construction phase of the applicable
leases. As a result, the Company currently has a $615,000 understatement for accrued rent on its balance sheet.

 The Company will take a one-time, pretax charge to its earnings in its next fiscal quarter, to be reported in its next Form 10-Q, to correct this error. Of the $615,000
pretax charge, $117,000 pertains to the current fiscal year. After tax, the charge equals $437,000, or $.09 per share, of which $83,000, or $.02 per share pertains to the current fiscal year. The Company and its auditors have evaluated the impact of
this issue on the Company’s financial statements for all applicable prior periods and have determined that the errors were not material.

 *******

 As requested in your letter, the Company hereby acknowledges that:

·
the Company is responsible for the adequacy and accuracy of the disclosures in its filings;

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

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

 We appreciate your assistance in enhancing the overall
disclosures in our public filings. If you have any additional questions or comments, please feel free to contact me.

 Very truly yours,

 FRISCH’S RESTAURANTS, INC.

 /s/ Donald H. Walker

 Donald H. Walker,

 Vice President-Finance and

 Chief Financial Officer

CC:
Craig F. Maier, CEO

 Sean McGrory, Grant
Thornton

 William A. Mauch, Audit Committee chairman

 Daniel W. Geeding, Audit Committee member

 Lorrence T. Kellar, Audit Committee member