Arcos Dorados

April 8, 2011

Re:     Arcos Dorados Holdings Inc. (the “Company”)

    Registration Statement on Form F-1

    Registration No. 333-173063

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Dear Sir/Madam:

In accordance with Rule 461 and Rule 430A under the Securities Act of 1933, as amended, the undersigned registrant hereby requests that the effective date for the Registration Statement referred to above be accelerated so that it will be declared effective at 4:00 P.M. Eastern Standard Time on April 8 or as soon thereafter as is practicable. By separate letter, the underwriters of the issuance of the securities being registered join in this request for acceleration.

We hereby acknowledge that:

• should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

• the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

*                    *                     *

Securities and Exchange Commission                                                 2

Sincerely, Arcos Dorados Holdings Inc.
By:	/s/    German Lemonnier
	Name:	German Lemonnier
	Title:	Chief Financial Officer

(Signature page to Acceleration Request)