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UPLOAD Filing

CHEESECAKE FACTORY INC
Date: Sept. 16, 2025 · CIK: 0000887596 · Accession: 0000000000-25-010032

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File numbers found in text: 000-20574

Date
September 16, 2025
Author
Division of
Form
UPLOAD
Company
CHEESECAKE FACTORY INC

Letter

Re: The Cheesecake Factory Incorporated Form 10-K for Fiscal Year Ended December 31, 2024 Form 8-K Furnished July 29, 2025 File No. 000-20574 Dear Matthew Clark:

September 16, 2025

Matthew Clark Chief Financial Officer The Cheesecake Factory Incorporated 26901 Malibu Hills Road Calabasas Hills, CA 91301

We have limited our review of your filing to the financial statements and related disclosures and have the following comment(s).

Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 8-K filed July 29, 2025 Exhibit 99.2 Investor Presentation July 29, 2025 Q2 2025 Highlights, page 28

1. We note you present in your investor presentation Adjusted EBITDA and Adjusted EPS here and on page 33, and Free Cash Flow on page 33. When presenting non- GAAP measures in your investor presentations, please present the most directly comparable GAAP measures. Refer to Rule 100(a)(1) of Regulation G. September 16, 2025 Page 2

In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please contact Robert Shapiro at 202-551-3273 or Patrick Kuhn at 202-551-3308 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Trade &
Services

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<TEXT>
 September 16, 2025

Matthew Clark
Chief Financial Officer
The Cheesecake Factory Incorporated
26901 Malibu Hills Road
Calabasas Hills, CA 91301

 Re: The Cheesecake Factory Incorporated
 Form 10-K for Fiscal Year Ended December 31, 2024
 Form 8-K Furnished July 29, 2025
 File No. 000-20574
Dear Matthew Clark:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 8-K filed July 29, 2025
Exhibit 99.2
Investor Presentation July 29, 2025
Q2 2025 Highlights, page 28

1. We note you present in your investor presentation Adjusted EBITDA and
Adjusted
 EPS here and on page 33, and Free Cash Flow on page 33. When presenting
non-
 GAAP measures in your investor presentations, please present the most
directly
 comparable GAAP measures. Refer to Rule 100(a)(1) of Regulation G.
 September 16, 2025
Page 2

 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Robert Shapiro at 202-551-3273 or Patrick Kuhn at
202-551-3308 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
</TEXT>
</DOCUMENT>