January 17, 2017

Via EDGAR

Ms. Melissa Raminpour

Ms. Effie Simpson

Division of Corporate Finance

Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549-7010

Mail Stop 3561

Dear Ms. Raminpour and Ms. Simpson:

On behalf of BJ’s Restaurants, Inc. (the “Company”), I am responding to the letter of Melissa Raminpour, Branch Chief – Office of Transportation and Leisure, dated December 16, 2016, relating to the above-referenced annual report on Form 10-K and periodic report on Form 8-K. Our responses are named and numbered to correspond with the names and numbers of the comments contained in your letter. For your convenience, we have included a copy of the text of your comment above each of our responses.

Comment:

Form 10-K for the year ended December 29, 2015

Consolidated Statements of Income, page F-3

1. We note your disclosure of your supply costs with Jamcar Companies, which is a related party. Please revise your consolidated statements of income to separately disclose cost of sales and occupancy and operating costs from related parties pursuant to Rule 4-08(k) of Regulation S-X.

Response:

We note the Staff’s comment and future filings will separately disclose cost of sales and occupancy and operating costs from related parties as well as trade payables due to related parties, if any. For your reference and information, a sample revised version of the Consolidated Balance Sheets, Consolidated Statements of Income and relevant section of Notes to Consolidated Financial Statements for the year ended December 29, 2015 reflecting the requested change is attached to this letter as Exhibit A.

Comment:

Form 8-K furnished on October 19, 2016

2. We note your presentation of Restaurant Level Operating Margin, which excludes general and administrative expenses and restaurant opening costs. Please revise future filings to provide a substantive and concise discussion of how Restaurant Level Operating Margin is useful to investors pursuant to Item 10(e)(1)(i)(C) of Regulation S-K Question 102.03 of the non-GAAP C&DIs. Your disclosure should explain which costs are not included in the measure and why. Additionally, please explain why you consider revenue to be the most directly comparable GAAP measure pursuant to Item 10(e)(1)(i)(A), such as income from operations. In your response, please provide us with proposed revisions to your current disclosures.

Response:

We note the Staff’s comment and will revise future filings to reflect the updated disclosure. The proposed revisions to the Company’s current disclosures regarding restaurant level operating margin are contained in Exhibit B, attached hereto. In considering the Staff’s comment, the Company recognizes that income from operations (a profitability measure) could be considered the most directly comparable GAAP measure since Restaurant Level Operating Margin represents the profitability derived from the revenues generated by the individual restaurants less their direct operating costs. As reflected in the attached Exhibit B, in future filings, the Company will revise its disclosure to include a reconciliation of Restaurant Level Operating Margin to income from operations.

In addition to our responses listed above to your comments, the Company acknowledges that it is responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the Staff.

Please do not hesitate to call me at (714) 500-2440 if you have any further comments or questions regarding this response.

We greatly appreciate you taking the time to review our filings and providing us the comments above so that we may improve our disclosures in our future filings.

EXHIBIT A

Sample Disclosure of Accounts Payable due to Related Parties

CONSOLIDATED BALANCE SHEETS

(In thousands)

The accompanying notes are an integral part of these consolidated financial statements.

Sample Disclosure of Cost of Sales and Occupancy and Operating Costs from Related Parties

CONSOLIDATED STATEMENTS OF INCOME

(In thousands, except per share data)

The accompanying notes are an integral part of these consolidated financial statements.

Sample Related Party Note to Consolidated Financial Statements

11. Related Party Transactions

The Jacmar Companies and their affiliates (collectively referred to herein as “Jacmar”) is one of our shareholders and James Dal Pozzo, the Chief Executive Officer of Jacmar, is a member of our Board of Directors. Jacmar, through its affiliation with DMA, is currently our largest supplier of food, beverage, paper products and supplies. We began using DMA for our national foodservice distribution in July 2006. In July 2012, we finalized a new five-year agreement with DMA, after conducting another extensive competitive bidding process. Jacmar services our restaurants in California and Nevada, while other DMA distributors service our restaurants in all other states. Under the terms of our agreement with DMA, Jacmar is required to sell products to us at the same prices as the other DMA distributors. Jacmar does not provide us with any produce, liquor, wine or beer products, all of which are provided by other third party vendors and are included in “Cost of sales” on the Consolidated Statements of Income.

The cost of food, beverage, paper products and supplies provided by Jacmar included within cost of sales and occupancy and operating expenses consisted of the following (in thousands):

The amounts included in trade payables related to Jacmar consisted of the following (in thousands):

EXHIBIT B

Proposed Revisions to Current Disclosure Regarding Restaurant Level Operating Margin

Restaurant Level Operating Margin

Restaurant level operating margin, a Non-GAAP financial measure, is equal to the revenues generated by our restaurants less their direct operating costs which consist of cost of sales, labor and benefits, and occupancy and operating costs. This performance measure includes only the costs that restaurant level managers can directly control and excludes other operating costs that are essential to conduct the Company’s business, as detailed in the table below. Management uses restaurant level operating margin as a supplemental measure of restaurant performance. Management believes restaurant level operating margin is useful to investors in that it highlights trends in our core business that may not otherwise be apparent to investors when relying solely on GAAP financial measures. Because other companies may calculate restaurant level margin differently than we do, restaurant level margin as presented herein may not be comparable to similarly titled measures reported by other companies.

A calculation of restaurant level operating margin and a reconciliation of restaurant level operating margin to income from operations for the third quarter and nine months ended September 27, 2016 and September 29, 2015 is set forth below:

Percentages above represent percent of total revenues and may not reconcile due to rounding.