November 21, 2024

Ravi Thanawala
Chief Financial Officer & EVP, International
Papa John's International, Inc.
2002 Papa John   s Boulevard
Louisville, Kentucky 40299

       Re: Papa John's International, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2023
           Form 10-Q for the Fiscal Quarter Ended September 29, 2024
           File No. 000-21660
Dear Ravi Thanawala:

       We have reviewed your filings 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.

Form 10-K for the Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Results of Operations
Operating Income by Segment, page 43

1.     You discuss the changes in adjusted operating income by segment, a
non-GAAP
       measure, without providing a similar discussion of the comparable GAAP
measure.
       Please revise to discuss the changes in operating income by segment with
equal or
       greater prominence. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and
Question
       102.10(a) of the Non-GAAP Financial Measures Compliance and Disclosure
       Interpretations. This comment also applies to your Forms 10-Q in fiscal
year 2024.
Consolidated Statements of Operations, page 58

2.     Please remove dividends declared per share from your consolidated
statements of
       operations and instead present this information in your consolidated
statements of
       stockholders' equity and/or footnotes. Similarly revise your Forms 10-Q
and earnings
 November 21, 2024
Page 2

       releases. Refer to ASC 505-10-S99-1, ASC 260-10-45-5 and SEC Release No.
33-
       10532.
Notes to Consolidated Financial Statements
7. Earnings Per Share, page 75

3.     We note that there are no adjustments for    dividends paid to
participating securities
       and    net income attributable to participating securities    to net
income attributable to
       the company in your earnings per share calculations for the year ended
December 31,
       2023. In addition, your disclosure in note 7 on page 14 of your 10-Q for
the quarterly
       period ended September 29, 2024 no longer indicates that you are
calculating earnings
       per share under the two-class method. Considering there appears to be
outstanding
       time-based restricted stock units at December 31, 2023 and restricted
stock units
       continue being issued during the fiscal year 2024, please tell us your
basis for no
       longer computing earnings per share under the two-class method.
        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.

       Please contact Suying Li at 202-551-3335 or Angela Lumley at
202-551-3398 if you
have any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services