September 13, 2019

Ken Kuick
Chief Financial Officer
Noodles & Company
520 Zang Street, Suite D
Broomfield, Colorado 80021

       Re: Noodles & Company
           Form 10-K for the Fiscal Year Ended January 1, 2019
           Form 10-Q for the Fiscal Quarter Ended July 2, 2019
           File No. 001-35987

Dear Mr. Kuick:

       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-K for the Fiscal Year Ended January 1, 2019

Risk Factors
We may be harmed by breaches of security of information technology systems...,
page 12

1.    We note the disclosure here that you dedicate significant resources to
preventing security
      breaches We also note that you "have experienced many attempts to
compromise [y]our
      information technology and data" and you " may experience more attempts
in the future."
       In light of the data breach that occurred in 2016 and resulted in
payments made through
      the year ended January 1, 2019, it appears that cybersecurity risks may
be material to your
      business. Please revise your Risk Factors section to discuss that
cybersecurity incident
      and its consequences as part of the broader discussion of the types of
potential
      cybersecurity incidents that pose material risks to your business and
operations. Your
      revised disclosure should consider this prior incident and its severity,
the probability of
      the occurrence and potential magnitude of cybersecurity incident, the
adequacy of
      preventative actions taken to reduce cybersecurity risks and the
associated costs, and the
 Ken Kuick
Noodles & Company
September 13, 2019
Page 2
         aspects of your business that give rise to material cybersecurity
risks and the potential
         costs and consequences of such risks. See Item 503(c) of Regulation
S-K and the
         Commission Statement and Guidance on Public Company Cybersecurity
Disclosures
         dated February 26, 2018.
Form 10-Q for the Fiscal Quarter Ended July 2, 2019

9. Leases, page 13

2.       We note your disclosure that some of your leases include rent
escalations based on
         inflation indexes and fair market adjustments and that certain leases
include contingent
         rental provisions that include a fixed base rent plus an additional
percentage of the
         restaurant's sales. We also note that you recognize these subsequent
escalations and
         contingent rental payments as variable lease expenses. Please revise
the table at the top of
         page 14, which details the components of lease costs, to include the
disclosure of variable
         lease expense, as well as short term lease expense. See ASC
842-20-50-4 for guidance.
3.       We note your disclosure that as most of the Company's leases do not
provide an implicit
         rate, you used the incremental borrowing rate based on the information
available at
         commencement date in determining the present value of lease payments.
For those leases
         that do provide an implicit rate, please tell us if you use the
implicit rate or incremental
         borrowing rate in calculating the present value of the lease payments.
        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 LastNameKen Kuick                                     Sincerely,
Comapany NameNoodles & Company
                                                                Division of
Corporation Finance
September 13, 2019 Page 2                                       Office of
Transportation and Leisure
FirstName LastName