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                             May 21, 2024

       Michael Healy
       Chief Financial Officer
       Bloomin' Brands, Inc.
       2202 North West Shore Boulevard, Suite 500
       Tampa, FL 33607

                                                        Re: Bloomin' Brands,
Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2023
                                                            Response dated May
7, 2024
                                                            File No. 1-35625

       Dear Michael Healy:

              We have reviewed your May 7, 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 April 23, 2024
       letter.

       Form 10-K for the Fiscal Year Ended December 31, 2023

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Adjusted Net Income and Adjusted Diluted Earnings Per Share Non-GAAP
Reconciliations,
       page 48

   1.                                                   We note your response
to prior comment 1. Your non-GAAP share adjustments appear to
                                                        have the effect of
changing the antidilutive provisions of FASB ASC 260-10-45 and are
                                                        therefore considered
individually tailored. Please revise your future disclosure to remove
                                                        the adjustments made to
exclude the dilutive effect of the shares to be issued upon
                                                        conversion of the 2025
Notes or further explain why you believe these are not tailored
                                                        measures. Refer to
Question 100.04 of the Non-GAAP Financial Measures Compliance
                                                        and Disclosure
Interpretations.
 Michael Healy
Bloomin' Brands, Inc.
May 21, 2024
Page 2


       Please contact Tony Watson at 202-551-3318 or Joel Parker at
202-551-3651 if you have
questions regarding comments on the financial statements and related matters.



FirstName LastNameMichael Healy                          Sincerely,
Comapany NameBloomin' Brands, Inc.
                                                         Division of
Corporation Finance
May 21, 2024 Page 2                                      Office of Trade &
Services
FirstName LastName