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                                                            December 3, 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 November 13, 2024
           File No. 001-35129
Dear Mariano Tannenbaum:

        We have reviewed your November 22, 2024 response to our comment letter
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.
Unless we note otherwise, any references to prior comments are to comments in
our
November 8, 2024 letter.

Form 20-F for Fiscal Year Ended December 31, 2023
Item 5. Operating and Financial Review and Prospects
B. Liquidity and Capital Resources, page 86

1.     We read your response to prior comment 4. Argentina and Venezuela appear
to have
       different risks. Please present the quantified disclosures for Argentina
separately from
       Venezuela. If you believe Venezuela's operations are not material at
this time, convey
       that in lieu of providing quantified disclosures for Venezuela.
 December 3, 2024
Page 2
Consolidated Financial Statements
Note 3. Summary of Significant Accounting Policies
Accounts Payable Outsourcing, page F-17

2.    We read your response to prior comment 6. Related to your accounts
payable
      arrangements, please also disclose whether:
          your accounts payable payment terms are consistent with industry
standards and
          those used by peer companies,
          different payment terms and/or purchase prices exist when suppliers
participate in
          the accounts payable services arrangements as compared to suppliers
that do not
          participate,
          you are permitted to remit payment to the financial institution or
the supplier on a
          date later than the original due date of the invoice under any
circumstances,
          you ever receive a fee, commission, refund or discount from the
financial
          institution (not limited to persuading suppliers to participate) and
          you retain the right to all early pay discounts offered by suppliers.

Form 6-K Submitted November 13, 2024
3Q 2024 Results
Consolidated Results
Adjusted EBITDA Bridge, page 6

3.    We read the disclosures you provided in response to prior comment 1.
Please discuss
      the comparable GAAP measures when you discuss adjusted EBITDA and
adjusted
      EBITDA margin.

       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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