October 18, 2024

Jeremiah Ashukian
Chief Financial Officer
Krispy Kreme, Inc.
2116 Hawkins Street
Charlotte, NC 28203

        Re: Krispy Kreme, Inc.
            Form 10-K for Fiscal Year Ended December 31, 2023
            Response Dated October 10, 2024
            File No. 001-40573
Dear Jeremiah Ashukian:

        We have reviewed your October 10, 2024 response to our comment letter
and have
the following comment(s).

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our
September 30, 2024 letter.

Form 10-K for Fiscal Year Ended December 31, 2023
Notes to Consolidated Financial Statements
Note 7 - Vendor Finance Programs
Supply Chain Financing Programs, page 74

1.     We have reviewed your response to prior comment 2. Please address the
following
       to clarify the difference between the contracts under the SCF program
and the
       contracts outside of the SCF program:
           You state in your response that your purchase contracts are
negotiated to
           minimize purchase prices and to obtain commercially reasonable
payment terms
           that are in line with industry peers. Tell us whether the prices and
payment terms
           of the vendors participating in the SCF program are in line with
your other
           vendors that do not participate in the SCF program;
 October 18, 2024
Page 2

             You state in your response that the payment terms of the purchase
contracts are
           not contractually conditioned upon a vendor   s participation in a
SCF program.
           However, on page 74 of your Form 10-K for the fiscal year ended
December 31,
           2023, you state that the    typical payment terms for trade payables
range up to 180
           days outside of the SCF program, depending on the type of vendors
and the nature
           of the supplies or services. For vendors under the SCF program, the
Company has
           established payable terms ranging up to, but not exceeding, 360
days.    Please
           resolve this discrepancy;
             You state in your response that there are no costs, interest, or
fees charged to you
           by the SCF provider. Clarify whether any fee is charged by your
vendors, which
           may be charged in the form of a higher price than they would charge
outside of
           the SCF provider. In this regard, during the earnings call for the
quarterly periods
           ended March 31, 2023 and June 30, 2023, Mr. Jeremiah Ashukian stated
that you
           were reducing your reliance on vendor financing as it became    a
more expensive
           way to provide financing.    In addition, he stated that the expense
from vendor
           financing hits adjusted EBITDA. Describe the expenses to which Mr.
Jeremiah
           Ashukian was referring; and
             You state in your response that some vendors no longer participate
in the SCF
           programs. Tell us whether the terms of your purchase contracts,
including prices
           and payment terms, have remained the same with these vendors before
and after
           their SCF program termination.

       Please contact Keira Nakada at 202-551-3659 or Angela Lumley at
202-551-3398 if
you have any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Trade &
Services