VIA EDGAR

September 23, 2025

Mr. Robert Shapiro

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Dear Mr. Shapiro:

Set forth below are the responses of The Cheesecake Factory Incorporated (the “Company”) to the comment received from the staff of the U.S. Securities and Exchange Commission (the “Staff”) in the Staff’s comment letter, dated September 16, 2025. For your convenience, we have repeated the Staff’s comments in italics followed by the Company’s response.

Form 8-K filed July 29, 2025

Exhibit 99.2

Investor Presentation July 29, 2025

Q2 2025 Highlights, page 28

The Company respectfully acknowledges the Staff’s comment. The Company confirms that it will include a presentation of Net Income/Loss, the most directly comparable GAAP measure to Adjusted EBITDA, a presentation of Net Income/Loss per share, the most directly comparable GAAP measure to Adjusted EPS, and a presentation of Cash provided by/used in operating activities, the most directly comparable GAAP measure to Free Cash Flow, alongside any presentation of Adjusted EBITDA, Adjusted EPS and Free Cash Flow, respectively, and any other most directly comparable GAAP measures when presenting non-GAAP measures in its future investor presentations.

Please contact me at (818) 871-3000 with any additional questions.