United States securities and exchange commission logo August 23, 2021 Carl Lukach Chief Financial Officer Noodles & Company 520 Zang Street, Suite D Broomfield, CO 80021 Re: Noodles & Company Form 10-K for the Fiscal Year Ended December 29, 2020 Filed February 26, 2021 Form 8-K filed August 3, 2021 File No. 1-35987 Dear Mr. Lukach: We have limited our review of your filings to the financial statements and related disclosures 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 8-K filed August 3, 2021 Exhibit 99.1 Key highlights for the second quarter of 2021 versus the second quarter of 2020 include:, page 1 1. You present restaurant contribution margin without providing the comparable GAAP measure with equal or greater prominence. Please revise to include the comparable GAAP measure. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the staff's Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Reconciliation of Net Income (Loss) to Adjusted Net Income (Loss), page 10 2. You state that the tax adjustments, net includes an adjustment to normalize the impact of the valuation allowance that affects your annual effective tax rate. Your valuation allowance adjustment appears to result in an individually tailored income tax recognition method. Please revise your presentation to omit this adjustment or tell us why you believe Carl Lukach Noodles & Company August 23, 2021 Page 2 it is appropriate. Refer to Question 100.04 of the staff's Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. In closing, 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 Tony Watson at (202) 551-3318 or Joel Parker at (202) 551-3651 with any questions. FirstName LastNameCarl Lukach Sincerely, Comapany NameNoodles & Company Division of Corporation Finance August 23, 2021 Page 2 Office of Trade & Services FirstName LastName