June 14, 2007

VIA EDGAR

Mr. David R. Humphrey
Branch Chief
Division of Corporate Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

Re:  Applebee's International, Inc.
     Form 10-K for the year ended December 31, 2006
     File No. 000-17962


Dear Mr. Humphrey:

We  have   reviewed  your  letter  dated  June  1,  2007  with  respect  to  the
above-referenced  report  filed  by  Applebee's  International,  Inc.  and  have
provided  responses to the comments in your letter.  For your  convenience,  the
original comments have been reproduced in their entirety and are followed by our
responses.

Form 10-K for the year ended December 31, 2006

Item 7. Management's Discussion and Analysis

Liquidity and Capital Resources, page 36

1.   We note from the balance  sheet  presentation  in your current and previous
     filings  that you have had negative  working  capital for at least the past
     four years.  Please revise your disclosure to discuss your negative working
     capital position as a known trend.  Although you have discussed the factors
     leading  to a decrease  in the  working  capital  deficit  (page 37),  this
     disclosure should include the facts and circumstances in both your business
     and the industry that may lead to such a deficit.  Refer to Item  303(a)(1)
     of  Regulation  S-K.  Please  also  consider  adding  this  measure to your
     Selected  Financial  Data as this  section  is meant to  highlight  certain
     significant trends in the registrant's  financial  condition and results of
     operations.

Response:

     We believe it is common for  companies  within the  restaurant  industry to
     operate with working capital deficits.  We operate with substantial working
     capital deficits as we carry low levels of accounts  receivable and most of
     our  revenues are received in cash or credit cards at the time of the sale.
     Historically,  we have used this cash to purchase  property and  equipment,
     repurchase our common stock and pay down  long-term  debt, all of which are
     non-current  in  nature.  We have  reviewed  Item  303(a)(1)  and in future
     filings we will include this  additional  disclosure  as a known trend.  In
     addition, we will add the working capital deficit to our Selected Financial
     Data.


Table of Contractual Obligations, page 38

2.   We note from your disclosure in Note 2 - Summary of Significant  Accounting
     Policies that you had  outstanding  checks creating a book overdraft in the
     amount of $13,430,000 that you have recorded as a liability at December 31,
     2006.  Please revise your table of contractual  obligations to include such
     overdrafts, as the written check represents a contractual arrangement.



Response:

     We  respectfully   note  your  comment,   however  the  book  overdraft  of
     $13,430,000  mentioned above was recorded in our consolidated balance sheet
     as of December 25, 2005,  not  December 31, 2006. A bank  overdraft  occurs
     when there is a negative  balance in a bank account  resulting  from checks
     which have been presented and cleared in excess of available  funds. A book
     overdraft  occurs when there is a negative balance (as in this case) in our
     general ledger bank account  resulting from checks written,  but which have
     not cleared the bank account.  We believe that if we had a bank  overdraft,
     it would represent a contractual obligation as the bank has extended credit
     creating a financing  activity.  However,  we believe a book  overdraft  is
     merely  a  financial  statement  presentation  matter  in our  consolidated
     balance sheet. In our case, there is no contractual  obligation between the
     bank and the company at the balance  sheet  date.  Consequently,  we do not
     believe it is appropriate to include the book overdraft in our  contractual
     obligations table in future filings.


Financial Statements

Footnotes to Financial Statements

Note 2 - Summary of Significant Accounting Policies

Revenue Recognition, page F-10

3.   Please tell us in your response and revise your  disclosure to indicate how
     you determine  the  likelihood  of gift card  redemption.  If you generally
     recognize  slippage income after a certain period of time,  please disclose
     such period of time.

Response:

     We determine our gift card slippage  income and the likelihood of gift card
     redemption based upon an analysis of our historical  redemption  experience
     using the  homogenous  pool  method.  We recognize  slippage  income over a
     two-year  period  beginning  one year after the sale of the gift  card.  In
     fiscal 2006, our gift card slippage income was approximately $1,200,000. In
     future filings,  we will incorporate  additional  disclosure  regarding our
     policy for recognizing gift card slippage  income,  including when we begin
     recognizing the income.


Advertising Costs, page F-10

4.   Please revise your  disclosure  here and throughout your filing to indicate
     ownership of the national  marketing pool. Such disclosure  should indicate
     whether you consolidate  the pool in your financial  statements and, if so,
     how  contributions  and  expenditures  of such  pool are  recorded  in your
     financial statements.

Response:

     The  national  marketing  pool  is  not  organized  as a  separate  entity.
     Therefore,  there  is no  ownership  to  disclose.  The  contributions  and
     expenditures   of  the  national   marketing   pool  are  included  in  our
     consolidated   financial  statements,   as  described  below.  We  and  our
     franchisees  contribute  a  percentage  of  restaurant  sales to a national
     marketing pool. In accordance  with SFAS 45,  "Accounting for Franchise Fee
     Revenue,"  we act as an  agent  for  our  franchisees  in  relation  to the
     national marketing pool and,  therefore,  no revenue or expense is recorded
     in our consolidated  statement of earnings for the franchisee  contribution
     to the pool.  The  company-owned  restaurant  contribution  to this pool is
     expensed as a direct and occupancy  cost in our  consolidated  statement of
     earnings.  Contributions  to the  national  marketing  pool are recorded in
     accrued expenses and other current liabilities in our consolidated  balance
     sheet. As we pay marketing invoices,  the liability is relieved.  In future
     filings, we will enhance our disclosure of our national marketing pool.


Note 10 - Goodwill and Other Intangible Assets, page F-24

5.   We note your disclosure here and elsewhere in your filing that you engage a
     third  party  independent  valuation  firm  to  assist  in the  fair  value
     determination of goodwill and other intangible  assets.  In future filings,
     please remove the reference to  independent  third party  participation  in
     your valuation process as such valuation should be management's assessment.
     In the alternative,  you may name such independent  third party and provide
     consent from such third party under  Exhibit 23.  Please note that,  if you
     wish to  incorporate  these  financial  statements  into  any  registration
     statement,  you must amend  these  statements  to name such third party and
     file a consent from the independent  party. Refer to Item 601 of Regulation
     S-K.

Response:

     The transaction that contained the above referenced  independent  valuation
     was recorded in 1988 and the net book value of the  franchise  interest and
     rights related to this transaction was $199,000 as of December 31, 2006. In
     future filings,  we will replace the reference to  "independent  valuation"
     with  "management's  assessment of the valuation."  While we have engaged a
     consultant to assist in the valuation  process,  the final  assessment  has
     always been made by management  and the  consultant's  input is only one of
     the  factors  considered.  As a result,  we believe  no  further  action is
     necessary  in order  to  continue  to  incorporate  our  annual  report  by
     reference in registration statements.


6.   Please tell us and revise  your  disclosure  to indicate  the nature of the
     intangible  assets not subject to amortization.  Refer to paragraphs 44 (b)
     and 45 (b) of  SFAS  142.  If the  entire  balance  relates  to  reacquired
     franchise rights, so state.

Response:

     Intangible assets not subject to amortization  include a tradename acquired
     in 2004 of  approximately  $2,900,000  and reacquired  franchise  rights of
     approximately  $490,000.  In future filings,  we will disclose the type and
     amount  recorded for each  intangible  asset not subject to amortization as
     referenced in paragraphs 44(b) and 45(b) of SFAS 142.

7.   Please  explain to us why you have not considered  Liquor  Licenses to be a
     part of your intangible asset balance.

Response:

     Liquor licenses in certain  jurisdictions  are in limited supply and can be
     sold and transferred in an open and active market.  We capitalize the costs
     of obtaining only these transferable liquor licenses in other assets in our
     consolidated  balance sheet. We believe that these transferable  restaurant
     assets are more  analogous  with the  characteristics  of assets  which are
     required to operate a  restaurant  rather than  corporate  intangibles.  We
     believe based upon our research that the presentation of capitalized liquor
     licenses in other assets in the consolidated balance sheet is common in our
     industry.


Note 18 - Commitments and Contingencies

Lease Guarantees and Contingencies, page F-30

8.   Please tell us in your response and revise your  disclosure to indicate why
     you  have  not  recorded  a  liability  related  to your  contingent  lease
     liabilities as of December 31, 2006 and 2005.


Response:

     In  connection  with the  sale of  restaurants  to  franchisees  and  other
     parties,  we have, in certain cases,  remained  contingently liable for the
     remaining  lease  payments.  The  effective  date and  transition  guidance
     provided  in  paragraph  20  of  FASB   Interpretation   No.   ("FIN")  45,
     "Guarantor's   Accounting  and  Disclosure   Requirements  for  Guarantees,
     Including   Indirect   Guarantees  of  Indebtedness  of  Others,"  requires
     prospective  application  for guarantees  issued or modified after December
     15, 2002. The sale of virtually all of the restaurants involving such lease
     contingencies  occurred  prior  to  the  effective  date  of  FIN  45  and,
     therefore,  we were not required to record a liability for these guarantees
     following the prospective  application guidance.  The fair value of the few
     remaining lease  guarantees  entered into after the adoption date of FIN 45
     are immaterial to our consolidated  financial statements.  We have complied
     with the disclosure requirements of FIN 45.

     In future  filings,  we will revise our  disclosure to indicate why we have
     not  recorded  a  liability  for  these  contingent  lease  liabilities  as
     discussed above.


Franchise Guarantees, page F-31

9.   We note your  disclosure  here that a total of $65.8 million is outstanding
     under the $250  million  franchise  development  program  funded by a third
     party for whom you guarantee  certain loans,  and that you have fair-valued
     your  guarantee at $130,000.  Please tell us and revise your  disclosure to
     indicate  the portion of the $65.8  million  loan  balance  outstanding  to
     franchisees from whom you have not yet been released of your guarantee.

Response:

     The amount of $65.8 million  outstanding  under the $250 million  franchise
     development  program is the total amount outstanding for which we provide a
     limited guarantee of 10%. As of December 31, 2006, we had not been released
     from any guarantees for any of the amount  outstanding.  In future filings,
     we will disclose  that the amount  outstanding  is net of amounts  released
     from our guarantee.


In providing our responses to your comments, we acknowledge that:

     o    we are  responsible for the adequacy and accuracy of the disclosure in
          the filing;

     o    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

     o    we 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.


Please contact me at (913) 967-4197 if you have any questions.

Sincerely,

APPLEBEE'S INTERNATIONAL, INC.

/s/ Steven K. Lumpkin

Steven K. Lumpkin
Executive Vice President and
Chief Financial and Strategy Officer