March 31, 2020

Joseph G. Taylor
Chief Financial Officer
Brinker International, Inc.
3000 Olympus Blvd
Dallas, TX 75019

       Re: Brinker International, Inc.
           Form 10-K for the Fiscal Year Ended June 26, 2019
           Filed August 22, 2019
           File No. 001-10275

Dear Mr. Taylor:

        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-K for Fiscal Year Ended June 26, 2019

Consolidated Statements of Comprehensive Income, page F-19

1.     We note your presentation of the sub-total "Company restaurant expenses"
on the face of
       your statements of comprehensive income and that this sub-total excludes
certain
       operating expenses for restaurant-related charges for impairments and
asset write-offs as
       detailed in note 5 on page F-37. We also note that the name of this
sub-total is very
       similar to the expense captioned "Restaurant expenses" included within
it. Please tell us
       your basis for presenting this sub-total and for excluding
restaurant-related charges from
       it.

       It appears from your disclosure on page F-53 that "Cost of sales" may
consist of food and
       beverage costs. If so, we believe you should consider retitling this
caption accordingly
       because your cost of sales expense is not burdened with other direct and
indirect costs of
       producing your food and beverage.
 Joseph G. Taylor
Brinker International, Inc.
March 31, 2020
Page 2
         Please revise the notes to your financial statements to narratively
describe the types of
         expenses included in "Restaurant expenses."
       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.

       You may contact Theresa Brillant at 202-551-3307 or Lyn Shenk at
202-551-3380 with
any questions.



FirstName LastNameJoseph G. Taylor                              Sincerely,
Comapany NameBrinker International, Inc.
                                                                Division of
Corporation Finance
March 31, 2020 Page 2                                           Office of Trade
& Services
FirstName LastName