March 4, 2005

Mail Stop 03-05

Via US Mail and Facsimile

Mr. Donald H. Walker
Vice President, Treasurer and Chief Financial Officer
2800 Gilbert Avenue
Cincinnati, Ohio 45206

Re:	Frisch`s Restaurants, Inc.
	Form 10-K for the year ended May 30, 2004
Forms 10-Q for the quarters ended September 19, 2004 and December
12,
2004
	Commission file #: 001-07323

Dear Mr. Walker:

We have reviewed your February 25, 2005 response letter and have
the
following comments.  Where expanded or revised disclosure is
requested, you may comply with these comments in future filings.
If
you disagree, we will consider your explanation as to why our
comments are inapplicable or a revision is unnecessary.  We also
ask
you to provide us with supplemental information so we may better
understand your disclosure.  Please be as detailed as necessary in
your explanation.  We look forward to working with you in these
respects and welcome any questions you may have about any aspects
of
our review.


* * * * * * * * * * * * * * * * * * * * * * *

Form 10-K for the year ended May 30, 2004

Notes to the Financial Statements

Note A.  Accounting Policies
- Self Insurance

1. We note from your response to comment 5 that you conduct a
quarterly analysis of claims experience, but actual reserve
adjustments are only performed on an annual basis.  Please
supplementally explain why you performed a quarterly analysis of
your
self-insurance claims experience but perform reserve adjustments
on
only an annual rather than quarterly basis.  If you do not believe
the results of the quarterly analysis would materially impact the
quarterly financial statements, provide us with quantified
information supporting your response.
Note C - Leased Property

2. We note from your response to comment 6 that you are currently
assessing the impact of conforming with paragraph 15 of SFAS No.
13
for leases with escalating payments over their terms.  If the
impact
is material to your results of operations for the affected period,
we
would expect you to account for any changes to your financial
statements as the correction of an error pursuant to paragraphs 36
and 37 of APB No. 20.  Please advise or revise as appropriate.


* * * * * * * * * * * * * * * * * * * * * * *

As appropriate, please respond to these comments within 10
business
days or tell us when you will provide us with a response.  Please
furnish a cover letter that keys your responses to our comments
and
provides any requested supplemental information.

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings reviewed by the staff to be
certain
that they have provided all information investors require for an
informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

You may contact Claire Lamoureux at 202-824-5663 or me at 202-942-
1936 if you have questions.
								Sincerely,


								Linda Cvrkel
								Branch Chief
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Frisch's Restaurants, Inc.
March 4, 2005
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