December 11, 2025

Raphael Duvivier
Chief Financial Officer
Krispy Kreme, Inc.
2116 Hawkins Street, Suite 101
Charlotte, North Carolina 28203

       Re: Krispy Kreme, Inc.
           Form 10-K for Fiscal Year Ended December 29, 2024
           File No. 001-40573
Dear Raphael Duvivier:

       We have reviewed your filing 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.

Form 10-K for Fiscal Year Ended December 29, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Non-GAAP Measures, page 40

1.     Please expand your footnote (2) on page 42 to quantify the components
included in
       the adjustment for strategic initiatives for all periods presented.
2.     Please quantify the components included in your tax specific adjustments
and tell us
       your purpose for including these adjustments in your non-GAAP measure
       presentation. Please explain why these adjustments do not substitute
individually
       tailored recognition and measurement methods for those of GAAP. Refer to
Question
       100.04 of the Non-GAAP Financial Measures Compliance and Disclosure
       Interpretations.
Results of Operations by Segment - Fiscal Year ended December 29, 2024 compared
to the
Fiscal Year ended December 31, 2023, page 48

3.     Segment Adjusted EBIT (rather than segment Adjusted EBITDA) appears to
be your
       primary measure of segment profitability under ASC 280. Please discuss
with
 December 11, 2025
Page 2

       quantification the business reasons for changes between periods in each
segment's
       Adjusted EBIT shown in Note 19 of your financial statements. Also
discuss with
       quantification the business reasons for changes between periods in Total
Corporate
       Expenses within Adjusted EBIT.
4.     Your segment adjusted EBITDA amounts appear to be non-GAAP measures.
Please
       revise to provide the disclosures required in Item 10(e) of Regulation
S-K for each
       segment non-GAAP measure.
Consolidated Financial Statements
Note 19 - Segment Reporting, page 104

5.     Please describe the adjustments applied on your significant segment
expenses for each
       reportable segment. Please disclose in greater detail with
quantification the specific
       types of material amounts included in Total Corporate Expenses within
Adjusted
       EBIT under your corporate reconciling line item. Refer to ASC
280-10-50-29(b) and
       50-31.
        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.

       Please contact Suying Li at 202-551-3335 or Rufus Decker at 202-551-3769
if you
have any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services