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June 7, 2024
Joseph Hummel
Chief Executive Officer
Twin Hospitality Group Inc.
5151 Belt Line Road, Suite 1200
Dallas, Texas 75254
Re:Twin Hospitality Group Inc.
Draft Registration Statement on Form 10-12B
Submitted May 13, 2024
CIK No. 0002011954
Dear Joseph Hummel:
            We have reviewed your draft registration statement and have the following comment(s).
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Draft Registration Statement on Form 10-12B
Cover Page
1.We note your disclosure that you will be a controlled company following the spin-off with
FAT Brands beneficially owning a to-be-determined percentage of the total voting power
of the outstanding shares of your common stock. Please revise here and wherever else you
discuss your controlled company status to state, if true, that FAT Brands will have the
ability to determine all matters requiring approval by stockholders.
Exhibit 99.1 Information Statement
Presentation of Certain Key Performance Indicators and Non-GAAP Financial Metrics
Comparable Restaurant Sales, page iii
2.We note your disclosure that "[c]onsistent with common industry practice, we present
Comparable Restaurant Sales on a calendar-adjusted basis that aligns current year sales
weeks with comparable periods in the prior year, regardless of whether they belong to the

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Twin Hospitality Group Inc.
June 7, 2024
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same fiscal period." Please further clarify this statement.
Our Company, page 7
3.We note your disclosure that you are the "franchisor and operator of two category-leading
casual dining restaurant concepts: Twin Peaks and Smokey Bones." Please revise to
clarify by what metric the concepts are "category-leading," such as by revenue, sales, etc.
4.We note your disclosure that you have more than 100 signed franchised units in your
development pipeline. To the extent possible, please revise to quantify the anticipated
timeline to bring these franchise units online. Additionally, we note that your disclosure
on page 39 that you have a historical franchise commitment-to-restaurant opening
conversion rate of approximately 66% for Twin Peaks restaurants. Please revise to balance
your development pipeline expectations with an anticipated timeline (near term and long
term) and expected conversion rate.
Expansion of our Smokey Bones Restaurant Footprint, page 19
5.We note your disclosure regarding potential Smokey Bones expansion
opportunities. Please reconcile or balance such disclosure with your current plans
to convert the majority of the acquired 61 Smokey Bones restaurants into new Twin Peaks
restaurants.
Organizational Structure, page 25
6.We note here and on page 73 that the diagram of your organizational structure indicates
that "[p]urchasers in this offering" will own a certain percentage of Twin Hospitality
Group, Inc.'s Class A Common Stock. We additionally note the disclosure on page F-8
that you are "contemplating an initial registration . . . that would involve the spin-off of
the Company from the Parent and a sale of a portion of the Parent’s equity ownership in
the Company to the public." Please advise or reconcile these disclosures which suggest a
sale of securities to the public with the contemplated spin-off transaction.
Summary Historical and Pro Forma Condensed Combined Financial Information and Other Data,
page 31
7.Please tell us how you determined that removing the non-cash portion of lease expenses in
arriving at Adjusted EBITDA does not substitute an individually-tailored recognition and
measurement method for GAAP, or remove the adjustment. Refer to Question 100.04 of
the Non-GAAP Financial Measures Compliance and Disclosure Interpretations
(C&DI's). Additionally, pre-opening expenses appear to represent normal operating
expenses necessary to operate your business, and therefore the adjustment is not consistent
with the guidance in Question 100.01 of the Non-GAAP C&DI's. Please revise.
8.Please expand your disclosure regarding the limitations on the usefulness of the non-
GAAP measure Restaurant-level EBITDA to emphasize that the excluded costs (i.e.,

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 Comapany NameTwin Hospitality Group Inc.
 June 7, 2024 Page 3
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Joseph Hummel
Twin Hospitality Group Inc.
June 7, 2024
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general and administrative expenses and pre-opening expenses) are essential to support
the operation and development of your restaurants.
Risk Factors
We have experienced and continue to experience inflationary conditions, page 41
9.We note your disclosure that in "the years ended December 31, 2023 and December 25,
2022, our costs from operations increased significantly" and that you "expect inflationary
pressures . . . to continue to impact [y]our business." To the extent possible, please revise
your disclosure here and in the MD&A section to quantify the impact of inflation and
provide year-by-year comparisons of this impact so that investors can understand the
nature and extent of the impact. Similarly, please provide additional detail regarding
any attempts to offset cost pressures through price increases, and indicate whether such
price increases have been successful.
We will have significant outstanding indebtedness under the Twin Securitization Notes . . ., page
47
10.We note your disclosure that "[i]f certain covenants are not met, the indebtedness may
become partially or fully due and payable on an accelerated schedule." Please revise
to briefly describe these "certain covenants." Additionally, please revise to quantify the
significant principal and interest payments which will be due following the
Reorganization.
If FAT Brands pursues the Potential FAT Brands Distribution . . ., page 56
11.To the extent true, please revise here to clarify that the conditions that you receive a
private letter ruling from the IRS as well as an opinion from outside counsel are waivable
conditions.
Unaudited Pro Forma Condensed Combined Financial Information, page 82
12.We note a column for adjustments relating to the reorganization and spin-off transaction;
however, there are no adjustments presented. Please advise.
Key Performance Indicators, page 88
13.When presenting a margin based on non-GAAP measures, please also present the most
directly comparable GAAP margin with equal or greater prominence. This comment also
applies throughout the filing when a non-GAAP margin is presented.

 FirstName LastNameJoseph Hummel
 Comapany NameTwin Hospitality Group Inc.
 June 7, 2024 Page 4
 FirstName LastName
Joseph Hummel
Twin Hospitality Group Inc.
June 7, 2024
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Business
Twin Peaks' Track Record of Robust Financial Performance and Growth, page 104
14.It appears your presentation of cash-on-cash returns for restaurants, calculated by dividing
Restaurant-Level EBITDA by your net initial investment after tenant allowances and sale
leaseback proceeds, is a non-GAAP measure. Please provide the information required by
Item 10(e) of Regulation S-K.
Twin Peaks' Market Opportunity, page 105
15.We note your disclosure comparing the company to the general full-service dining
industry and casual dining segment but we also note that you operate in the sports bar sub-
segment. Please balance any comparison disclosure with additional details regarding the
company's performance within the sports bar sub-segment.
Differentiated Customer Experience Generating Industry-Leading Guest Satisfaction, page 108
16.We note that the metrics disclosed in this section compare the company to the broader
casual dining segment and general restaurant industry. We also note your disclosure that
the company operates within the sports bar sub-segment. To the extent available, please
provide comparable information related to the company's scores in the sports bar sub-
segment.
Management
Executive Officers, Non-Executive Directors, and Non-Executive Director Nominees, page 127
17.Please revise here or in another section to identify the members of your board and
management who will hold position at related entities. In this regard, we note your
disclosure on page 58 that "[t]wo of our director nominees are also directors of FAT
Brands, and own stock options to purchase shares of Class A common stock of FAT
Brands."
General
18.In an appropriate place, please address whether FAT Brands will continue to trade on
Nasdaq under the ticker symbol "FAT." Consider adding a question and answer regarding
the continued trading of FAT Brands.

 FirstName LastNameJoseph Hummel
 Comapany NameTwin Hospitality Group Inc.
 June 7, 2024 Page 5
 FirstName LastName
Joseph Hummel
Twin Hospitality Group Inc.
June 7, 2024
Page 5
            Please contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at 202-551-3307 if
you have questions regarding comments on the financial statements and related matters. Please
contact Rucha Pandit at 202-551-6022 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       William Wong