August 23, 2019

F. Mark Wolfinger
Chief Financial Officer
Denny's Corporation
203 East Main Street
Spartanburg, South Carolina 29319-0001

       Re: Denny's Corporation
           Form 10-K for the Fiscal Year Ended December 26, 2018
           Form 10-Q for the Fiscal Quarter Ended June 26, 2019
           File No. 000-18051

Dear Mr. Wolfinger:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-Q for the Fiscal Quarter Ended June 26, 2019

Financial Statements
Notes to Condensed Consolidated Financial Statements
Note 3. Leases, page 10

1.    We note your disclosure that you have certain lease agreements structured
with a fixed
      base rent adjusted periodically for inflation or changes in fair market
value of the
      underlying real estate. Please provide us with additional details
regarding the terms of the
      rent adjustments including the basis for determining the adjustments.
Please also tell us
      how you are accounting for leases structured with these adjustments both
at the
      commencement of the lease and subsequently. Specifically address whether
any of these
      lease agreements include variable lease payments that depend on an index
or a rate.


2.    We note from your disclosure on page 10 that the weighted-average
discount rate used for
      finance leases is 24.3% and the weighted-average discount rate used for
operating leases
 F. Mark Wolfinger
Denny's Corporation
August 23, 2019
Page 2
         is 6.7%. Please provide us with additional details regarding how you
determined or
         calculated the weighted-average discount rates for each class of your
leases.
Note 4. Refranchisings and Acquisitions, page 12

3.       We note your disclosure that in addition to cash proceeds received on
the sale of real
         estate in the first quarter of 2019, you recorded additional noncash
consideration for the
         fair value of restaurant space you expect to receive within a building
being developed by
         the buyer of the real estate. We also note your disclosure that the
fair value of the noncash
         consideration is based upon Level 2 inputs. Please explain to us and
revise to disclose the
         nature of the valuation technique(s) and inputs used in the fair value
measurement. See
         guidance in ASC 820-10-50-2(bbb). Also, please provide these
disclosures for the fair
         value of the assets held for sale as of March 27, 2019.
        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 Heather Clark at 202-551-3624 or Claire Erlanger at
202-551-3301 with
any questions.



FirstName LastNameF. Mark Wolfinger                            Sincerely,
Comapany NameDenny's Corporation
                                                               Division of
Corporation Finance
August 23, 2019 Page 2                                         Office of
Transportation and Leisure
FirstName LastName