United States securities and exchange commission logo





                              September 2, 2020

       Tonya Robinson
       Chief Financial Officer
       Texas Roadhouse, Inc.
       6040 Dutchmans Lane, Suite 200
       Louisville, Kentucky 40205

                                                        Re: Texas Roadhouse,
Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2019
                                                            Filed February 28,
2020
                                                            File No. 000-50972

       Dear Ms. Robinson:

             We have reviewed your filing and have the following comment. In
our comment, 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 the Fiscal Year Ended December 31, 2019

       Consolidated Financial Statements
       Consolidated Statements of Income and Comprehensive Income, page F-6

   1.                                                   It appears from your
disclosure on page 39 that cost of sales may consist of food and
                                                        beverage costs. If so,
we believe you should consider retitling this caption accordingly,
                                                        because your cost of
sales is not burdened with other direct and indirect costs of producing
                                                        your food and
beverages.
               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.
 Tonya Robinson
Texas Roadhouse, Inc.
September 2, 2020
Page 2

        You may contact Aamira Chaudhry at (202) 551-3389 or Rufus Decker at
(202) 551-
3769 if you have any questions.



FirstName LastNameTonya Robinson                        Sincerely,
Comapany NameTexas Roadhouse, Inc.
                                                        Division of Corporation
Finance
September 2, 2020 Page 2                                Office of Trade &
Services
FirstName LastName