April 22, 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 reviewed your April 9, 2020 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to
comments in our
March 31, 2020 letter.

Form 10-K for the Fiscal Year Ended June 26, 2019

Consolidated Statements of Comprehensive Income, page F-19

1.     We note your response regarding the presentation of the sub-total
"Company restaurant
       expenses" on the face of your statements of comprehensive income. You
state the
       subtotal captures expenses directly related to sales for the period.
However, the subtotal
       excludes depreciation and other costs, such as remodel costs, that
appear to be directly
       related to restaurant sales (in addition to the excluded items noted in
our prior comment).
       In addition, as we previously noted, the name of this sub-total is very
similar to the
       expense captioned "Restaurant expenses" included within it. We believe
that a sub-total
       quantifying the components of the leading caption "Company restaurants
(excluding
       depreciation and amortization)" should not be presented on the face of
the statement for
       the aforementioned reasons. We would not object to your continued
indentation of food
 Joseph G. Taylor
Brinker International, Inc.
April 22, 2020
Page 2
         and beverage costs, restaurant labor, and restaurant expenses under
the leading caption.
       You may contact Theresa Brillant at 202-551-3307 or Lyn Shenk at
202-551-3380 if you
have any questions.



FirstName LastNameJoseph G. Taylor                            Sincerely,
Comapany NameBrinker International, Inc.
                                                              Division of
Corporation Finance
April 22, 2020 Page 2                                         Office of Trade &
Services
FirstName LastName