SecProbe.io

January 24, 2011
   Ms. Debby R. Zurzolo Executive Vice President, Secr etary and General Counsel
The Cheesecake Factory Incorporated
26901 Malibu Hills Road Calabasas Hills, CA 91301
Re: The Cheesecake Factory Incorporated
 Form 10-K for the Year Ended December 29, 2009
Filed February 26, 2010 Definitive Proxy Statement on Schedule 14A Filed April 23, 2010 File No. 000-20574

Dear Ms. Zurzolo:
We have reviewed your responses to the co mments in our letter dated December 16, 2010
and have the following additional comments.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Definitive Proxy Statement on Schedule 14A

Fiscal 2009 Award Program under the 2005 Incentive Plan, page 48

1. We note your response to our prior comment  one and we also note that you have
provided the targets in your response to our comment letter.  Please confirm that you will
disclose these targets in your future filings.

2. Additionally, please expand your ju stification for your belief th at disclosure of company-
wide targets may be omitted due to the risk  of competitive harm.  For example, in your
revised analysis, please tell us how disclo sing the components of your Core G&A plus
Indirect Pre-Opening Costs as a Percentage of Sales would provide information to your

Debby R. Zurzolo The Cheesecake Factory Incorporated January 24, 2011 Page 2

competitors regarding “specific infrastructure strategies” and “margin leverage
opportunities, and whether those strategies remain in plac e and/or continue to be
effective” and how your competitors could us e this information “to hire away key
personnel and to identify busin ess development opportunities w ith respect to which [you]
may currently have a competitive advantage.”  Additionally, please tell us how disclosing
the list of publicly-held, casual dining rest aurants used to compare the mean of your
operating margin would cause you serious comp etitive harm by disclosing the companies
you consider to be your direct competitors to the restaurant  industry.  For guidance refer
to Compliance and Disclosure Interpretation 118.04 of  Regulation S-K.  Finally, to the
extent that it is appropriate to omit specific ta rgets, please advise us of the disclosure that
the company will provide pursuant to Instruc tion 4 to Item 402(b) of Regulation S-K.

 In responding to our comments, please provi de a written statement from the company
acknowledging that:

• the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

Please contact Tonya Bryan at 202-551-3601 or me at 202-551-3574 with any questions.

Sincerely,

Julie F. Rizzo Attorney-Advisor
cc (via fax):   Ms. Debby R. Zurzolo  (818) 871-8325