SecProbe.io

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      June 30, 2005

By U.S. Mail and Facsimile [(310)568-7720]

Mail Stop 3561

Ms. Susan M. Collyns
Principal Financial and Accounting Officer
California Pizza Kitchen, Inc.
6053 West Century Boulevard, 11th Floor
Los Angeles, California 90045-6438

Re:	California Pizza Kitchen, Inc.
	Form 10-K for the fiscal year ended January 2, 2005
      Filed April 4, 2005
	File No. 000-31149

Dear Ms. Collyns:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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 filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

* * * * *

Form 10-K (Fiscal year ended January 2, 2005)

Item 1.  Business
Unit Level Economics, page 7
1. We note your presentation of restaurant-level operating margin
percentages within your discussion of unit level economics.
Please
revise this discussion, as appropriate, after you consider the
following comment regarding the presentation of non-GAAP financial
measures.

Management`s Discussion and Analysis
Results of Operations, page 23
2. In light of the issuance of FR-65, and the related guidance
made
available by the Division of Corporation Finance on June 13, 2003,
we
believe you should discontinue your presentations of restaurant
operating margins and restaurant operating margin percentages.  In
this regard, our principal objection is to the exclusion of
general
and administrative expenses.  Since the volume and timing of newly
opened restaurants can have a material impact on your results of
operations, the general and administrative costs that support
existing operations and provide infrastructure to facilitate
future
growth should be included in any measure of profitability or
performance.

Consolidated Financial Statements
Consolidated Statements of Income, page 40
3. Please consider the propriety of presenting "total restaurant
operating costs" in light of the fact that your general and
administrative costs support your restaurant operations.  Also,
pre-
opening expenses and store closure costs, as well as the legal
settlement reserve recorded in your most recent fiscal year, are
all
related to your restaurant operations.

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, 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 filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; 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 filing or in
response to our comments on your filing.

	You may contact Ms. Kristin Shifflett, Staff Accountant, at
(202) 551-3381, if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
551-3211 with any other questions.

Sincerely,

      David R. Humphrey
							Accounting Branch Chief
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June 30, 2005
Ms. Susan Collyns
California Pizza Kitchen, Inc.
Page 1

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