SecProbe.io

September 23, 2019
Christopher Pappas
Chairman, President and Chief Executive Officer
The Chefs' Warehouse, Inc.
100 East Ridge Road
Ridgefield, Connecticut 06877
Re:The Chefs' Warehouse, Inc.
Form 10-K For Fiscal Year Ended December 28, 2018
Filed March 1, 2019
File No. 1-35249
Dear Mr. Pappas:
            We have reviewed your filing and have the following comment.  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 comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended December 28, 2018
Note 2-Summary of Significant Accounting Policies
Goodwill, page 56
1.You indicate that "In the fourth quarter of 2018, the Company reevaluated its operating
segments to align with how the Company's chief operating decision maker evaluates
performance and allocates resources.  This analysis resulted in a change from two
reporting units, Protein and Specialty, to three reporting units, East Coast, Midwest and
West Coast."   We interpret this disclosure to mean you changed your operating segments
from two to three segments and that your operating segments represent your reporting
units.  If our understanding is incorrect, please clarify our understanding as to what you
meant by this disclosure and define your operating segments. On page 52, you disclose
that you operate in one reportable segment, food product distribution.  If your current
business consists of three operating segments, please address in detail how you met the
aggregation criteria in ASC 280-10-50-11 for your revised operating segments.   If the

 FirstName LastNameChristopher Pappas
 Comapany NameThe Chefs' Warehouse, Inc.
 September 23, 2019 Page 2
 FirstName LastName
Christopher Pappas
The Chefs' Warehouse, Inc.
September 23, 2019
Page 2
Protein and Speciality reporting units comprised separate operating segments in prior
years, please advise how those units met the aggregation criteria in ASC 280-10-50-11 in
prior years.   In any event, please ensure your financial statements clearly disclose your
identified operating segments as distinguished from your reporting units and consider
discussing your results of operations on an operating segment basis, if appropriate.
Finally, please provide the history of your determination of operating and reportable
segments from the point you became a reporting company to the most recent annual
financial statements.  We may have further comment.
            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.
            You may contact Yolanda Guobadia, Staff Accountant, at (202) 551-3562 or Jim
Allegretto, Senior Assistant Chief Accountant, at (202) 551-3849 with any questions.
Sincerely,
Division of Corporation Finance
Office of Consumer Products
cc:       Alexandros Aldous