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                                                           November 8, 2024

Mariano Tannenbaum
Chief Financial Officer
Arcos Dorados Holdings Inc.
R  o Negro 1338, First Floor
Montevideo, Uruguay 11100

       Re: Arcos Dorados Holdings Inc.
           Form 20-F for Fiscal Year Ended December 31, 2023
           Form 6-K Submitted August 14, 2024
           File No. 001-35129
Dear Mariano Tannenbaum:

       We have reviewed your filings and have the following comment(s).

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 20-F for Fiscal Year Ended December 31, 2023
Item 3. Key Information
A. Selected Financial Data, page 2

1.     When you present and/or discuss non-GAAP measures, please also present
and/or
       discuss the comparable GAAP measures. Please present net income
attributable to
       Arcos Dorados Holdings Inc. and its margin on page 5 of your Form 20-F,
where total
       adjusted EBITDA and its margin are presented. Also, both the Form 6-K
submitted
       August 14, 2024 and the investor presentation on your website dated
August 14,
       2024 should be revised, as applicable, to:
           Present year-over-year growth in net income attributable to Arcos
Dorados
           Holdings Inc., if you present year-over-year growth in consolidated
adjusted
           EBITDA;
           Present the net debt to net income attributable to Arcos Dorados
Holdings Inc.
           ratio, if you present the net debt to adjusted EBITDA leverage
ratio;
           Present and discuss net income attributable to Arcos Dorados
Holdings Inc. and
           its margin, if you present and discuss total adjusted EBITDA and its
margin; and
 November 8, 2024
Page 2

             Start the adjusted EBITDA reconciliation with net income
attributable to Arcos
           Dorados Holdings Inc., rather than operating income.
       Refer to Item 10(e)(1)(i) of Regulation S-K, Rule 100(a) of Regulation G
and
       Question 103.02 of the Non-GAAP Financial Measures Compliance and
Disclosure
       Interpretations, as applicable.
2.     Please present corporate and others (and purchase price allocation, when
applicable)
       margin in the tables showing operating margins and adjusted EBITDA
margins.
Item 5. Operating and Financial Review and Prospects
A. Operating Results
Results of Operations
Year Ended December 31, 2023 Compared to Year Ended December 31, 2022
Sales by Company-Operated Restaurants , page 73

3.     Please separately quantify the impact of increase in traffic and
increase in average
       check to which you attribute a material increase in revenue.
B. Liquidity and Capital Resources, page 86

4.     Please revise to discuss with quantification the liquidity and capital
resources
       implications related to your material operations in highly inflationary
environments
       (i.e., Venezuela and Argentina). If there are restrictions on cash
remitances to you
       from your operations in these highly inflationary environments, please
also discuss
       these restrictions (or refer here to disclosure provided elsewhere in
the filing, as
       applicable) and quantify the amounts of cash and cash equivalents (and
other highly-
       liquid assets) in each highly inflationary country. Refer to FRR Section
       501.09.b and Item 303 of Regulation S-K, including, but not limited to,
Instruction 9
       to paragraph (b).
Consolidated Financial Statements
Consolidated Statements of Cash Flows, page F-9

5.     Please present changes in inventories separately in your reconciliation
to net cash
       provided by operating activities. Refer to ASC 230-10-45-29. Also,
present financing
       cash flows related to derivative instruments on a gross, rather than
net, basis. Refer to
       ASCs 230-10-45-7 through 45-9 and ASCs 230-10-45-14(d) and 45-15(d).
Note 3. Summary of Significant Accounting Policies
Accounts Payable Outsourcing, page F-17

6.     Please tell us whether you pay any fees related to the supplier finance
program. If so,
       disclose the nature, frequency and amounts of the fees. Also, provide a
rollforward of
       the obligations in the footnote. Refer to ASC 405-50-50-3.
Note 21. Segment and Geographic Information, page F-47

7.     Please disclose the amounts of revenues and long-lived assets for each
country that
       is material (e.g., Argentina, Mexico and/or Chile). Refer to ASC
280-10-50-41.
 November 8, 2024
Page 3

        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.

       Please contact Keira Nakada at 202-551-3659 or Rufus Decker at
202-551-3769 if
you have any questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Trade &
Services
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