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June 21, 2021
Ann Gugino
Chief Financial Officer
Papa John's International, Inc.
2002 Papa John’s Boulevard
Louisville , Kentucky 40299
Re:Papa John's International, Inc.
Form 10-K for the Fiscal Year Ended December 27, 2020
Filed February 25, 2021
File No. 000-21660
Dear Ms. Gugino:
            We have reviewed your registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 27, 2020
Discussion of Operating Results, page 37
1.Please revise the bolded table caption "Adjusted operating income" to "Total" or
something similar to avoid labeling each column total as "Adjusted operating income."

 FirstName LastNameAnn Gugino
 Comapany NamePapa John's International, Inc.
 June 21, 2021 Page 2
 FirstName LastName
Ann Gugino
Papa John's International, Inc.
June 21, 2021
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Discussion of Operating Results
North American Franchising Segment, page 37
2.Please quantify factors to which changes are attributed. For example, you state the
increase in North America Franchising Segment was due to higher comparable sales and a
higher effective royalty rate.  Refer to Item 303(b) of Regulation S-K.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Caroline Oyler