December 11, 2018

Gunther Plosch
Chief Financial Officer
The Wendy's Company
One Dave Thomas Blvd.
Dublin, Ohio 43017

       Re: The Wendy's Company
           Form 10-Q for the Fiscal Quarter Ended September 30, 2018
           Filed November 6, 2018
           File No. 001-02207

Dear Mr. Plosch:

        We have limited our review of your filing to the financial statements
and related
disclosures 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-Q for the quarter ended September 30, 2018

System Optimization (Gains) Losses, Net, page 16

1.    We note you plan to continue to optimize your system in part through
strategic
      dispositions of company-operated restaurants to existing and new
franchisees, and that
      you completed the sale of three restaurants during the nine months ended
September 30,
      2018. Please tell us how you determined the portion of the consideration
that is
      attributable to the franchise arrangement(s) separate from the
business(es) being sold (i.e.
      the amount allocated to the franchise right). If the amount deferred is
the standard
      franchise up-front fee, please explain why you believe this is
appropriate.


       In closing, 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.
 Gunther Plosch
The Wendy's Company
December 11, 2018
Page 2

       You may contact Theresa Brillant at 202-551-3307 or Jean Yu at
202-551-3305 with any
questions.



FirstName LastNameGunther Plosch                        Sincerely,
Comapany NameThe Wendy's Company
                                                        Division of Corporation
Finance
December 11, 2018 Page 2                                Office of
Transportation and Leisure
FirstName LastName