SecProbe.io

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								June 6, 2005
Zip+4 Code:  20549-0305

Via Fax & U.S. Mail

Mr. Ricardo Figueiredo Bomeny
Chief Executive Officer
Av. Brasil
6431 - Bonesucesso
CEP 21040 -360
Rio de Janeiro, Brazil

RE:	Brazil Fast Food Corporation (the "Company")
	Form 10-K for the year ended December 31, 2004
	File No. 000-23278

Dear Mr. Bomeny:

Based upon an examination restricted solely to considerations of
the
Financial Statements, Management`s Discussion and Analysis, and
Selected Financial Data, the staff has the following comments on
the
above-referenced documents.  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.

Business - Page 2

1. We note your discussion regarding the rescheduling of of debts
"long overdue" by certain franchisees in your business section and
note that franchisee receivables are material to your financial
statements. Please tell us supplementally the amount of reserves
that
are recorded against these overdue receivables and provide us with
your evaluation and conclusions that these amounts are realizable.

Liquidity and Capital Resources

Contractual Obligations - page 33

2. As this table is intended to increase the transparency of cash
flow, we believe that registrants should generally include
scheduled
interest payments in the table.  Where interest rates are variable
and
unknown, you may use your judgment to determine whether or not to
include such estimates.  If you elect to include them, you may
determine the appropriate methodology to estimate the interest
payments.  Regardless of whether you include interest payments or
not,
a footnote to the table should clarify whether or not you have
done so
and, if applicable, the methodology you have used in your
estimate.
If interest payments are excluded from the table, please disclose
the
significant contractual terms of the debt and any other additional
information that is material to an understanding of these future
cash
flows.  Please revise accordingly in future filings.

Financial Statements

Consolidated Statements of Operations - page F-5

3. We believe that your income statement format should comply more
closely with the guidance set forth in Rule 5-03 of Regulation S-
X.
Specifically, we would generally expect to see a total for net
sales
and gross revenues presented, as specified by Rule 5-03 (b) (1).
Your
various operating costs and expenses should follow.  In this
regard,
it appears that certain of the charges currently classified
outside of
the caption "Total Store Costs and Expenses" are also associated
with
store-related activities.  For example, it appears that the
salaries
of individuals who make decisions about opening, closing and
restructuring your stores may not be considered in your
presentation
of "Store Operating Income."  We believe that a format more
comparable
to the presentation on page 20 of your filing would be more
appropriate.  Finally, we would not expect the balances of the
individual line items in your selected financial data to differ
from
your income statement balances.  Please revise or advise.

Please note that we will not object if you wish to augment your
MD&A
to also include a separate discussion of the impact of your
franchise
operations where you believe the information would be appropriate
to
an understanding of your business.

* * * * *

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 on any other aspect of our review.
Feel
free to call us at the telephone numbers listed at the end of this
letter.

Please respond to confirm that such comments will be complied
with,
or, if certain of the comments are deemed inappropriate by the
Company, advise the staff of the reason thereof.

Pursuant to Rule 101(a)(3) of Regulation S-T, your response should
be
submitted in electronic form, under the label "corresp" with a
copy to
the staff.  After our review of your supplemental replies, we may
have
further comments.  Please respond within fifteen (15) business
days.

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.

You may contact Rob Perdue at (202) 551-3303 or Margery Reich, at
(202) 551-3347 if you have questions regarding comments on the
financial statements and related matters.  Please contact the
undersigned at (202) 551-3816 with any other questions.

								Sincerely,

								Joseph A. Foti
								Senior Assistant Chief
Accountant

Via facsimile:  Mr. Ricardo Figueiredo Bomeny, CEO & CFO

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Mr. Ricardo Figueiredo Bomeny
Brazil Fast Food Corporation
June 6, 2005
Page 1

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