September 24, 2019

R. Steve Kinsey
Chief Financial Officer and Chief Administrative Officer
Flowers Foods, Inc.
1919 Flowers Circle
Thomasville, Georgia 31757

       Re: Flowers Foods, Inc.
           Form 10-K for Fiscal Year Ended December 29, 2018
           Filed February 20, 2019
           Form 10-Q for Fiscal Quarter Ended July 13, 2019
           Filed August 7, 2019
           Form 8-K dated August 8, 2019
           File No. 001-16247

Dear Mr. Kinsey:

       We have reviewed your filing 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

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

Form 10-Q for Fiscal Quarter Ended July 13, 2019

Note 1. Basis of Presentation
Reporting Segment, page 9

1.     We note you have one operating segment under your new organizational
structure, which
       consists of two business units identified as Fresh Packaged Bread and
Snacking/Specialty.
       Your disclosure explains that this conclusion is "based on the nature of
products the
       company sells, intertwined production and distribution model, the
internal management
       structure and information that is regularly reviewed by the chief
executive officer
       ("CEO"), who is the chief operating decision maker, for the purpose of
assessing
       performance and allocating resources." Please provide us with your new
operating
       segment analysis under ASC 280-10-50-1. As part of your response,
address the
 R. Steve Kinsey
FirstName LastNameR. Steve Kinsey
Flowers Foods, Inc.
Comapany 24, 2019
September NameFlowers Foods, Inc.
September 24, 2019 Page 2
Page 2
FirstName LastName
         following:

             Tell us more about how your new internal management structure is
organized,
             including the title and role of each of the individuals who report
to the chief operating
             decision maker ("CODM"); and

             Identify and describe the role of the segment manager as
contemplated by ASC 280-
             10-50-6 through 50-9;

             Tell us how often the CODM meets with direct reports, the
financial information the
             CODM reviews to prepare for those meetings, the financial
information discussed in
             those meetings, and any other personnel who attend those meetings;

             Tell us whether or not there are individuals held specifically
accountable for each of
             the two new business units;

             Describe the contents of the discrete financial information that
is reviewed by your
             CODM to allocate resources and assess performance, and indicate
the frequency with
             which such information is prepared; and,

             Describe the information regularly provided to the Board of
Directors and how
             frequently it is prepared.
Form 8-K dated August 8, 2019

Exhibit 99
Information Regarding Non-GAAP Financial Measures

2.       We note your definition of EBITDA under this heading differs from the
definition
         provided in the Form 8-K filed February 6, 2019 under the same
heading, and the
         definition provided on page 4 of your Form 10-K for the fiscal year
ended December 29,
         2018. Additionally, we note that these definitions do not appear to
use "earnings" as
         defined in Question 103.01 of the Compliance and Disclosure
Interpretations Non-GAAP
         Financial Measures updated April 4, 2018. Please ensure that measures
of EBIT or
         EBITDA calculated differently from those described in Question 103.01
not be
         characterized as such.
Reconciliation of Earnings per Share - Full Year Fiscal 2019 Guidance

3.       We note your reconciliation of earnings per share for the full year
fiscal 2019 guidance
         contains only one adjustment for "Matters affecting comparability."
Please revise this
         presentation to provide more specificity with respect to each
adjustment. Refer to Item
         10(e)(1)(i)(B) of Regulation S-K.
 R. Steve Kinsey
Flowers Foods, Inc.
September 24, 2019
Page 3

        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 Jennifer O'Brien, Staff Accountant, at 202-551-3721 or
Kimberly
Calder, Assistant Chief Accountant, at 202-551-3701 if you have any questions.



FirstName LastNameR. Steve Kinsey                         Sincerely,
Comapany NameFlowers Foods, Inc.
                                                          Division of
Corporation Finance
September 24, 2019 Page 3                                 Office of Natural
Resources
FirstName LastName