September 23, 2019

Christopher Pappas
Chairman, President and Chief Executive Officer
The Chefs' Warehouse, Inc.
100 East Ridge Road
Ridgefield, Connecticut 06877

       Re: The Chefs' Warehouse, Inc.
           Form 10-K For Fiscal Year Ended December 28, 2018
           Filed March 1, 2019
           File No. 1-35249

Dear Mr. Pappas:

       We have reviewed your filing and have the following comment. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 28, 2018

Note 2-Summary of Significant Accounting Policies
Goodwill, page 56

1.    You indicate that "In the fourth quarter of 2018, the Company reevaluated
its operating
      segments to align with how the Company's chief operating decision maker
evaluates
      performance and allocates resources. This analysis resulted in a change
from two
      reporting units, Protein and Specialty, to three reporting units, East
Coast, Midwest and
      West Coast." We interpret this disclosure to mean you changed your
operating segments
      from two to three segments and that your operating segments represent
your reporting
      units. If our understanding is incorrect, please clarify our
understanding as to what you
      meant by this disclosure and define your operating segments. On page 52,
you disclose
      that you operate in one reportable segment, food product distribution. If
your current
      business consists of three operating segments, please address in detail
how you met the
      aggregation criteria in ASC 280-10-50-11 for your revised operating
segments. If the
 Christopher Pappas
The Chefs' Warehouse, Inc.
September 23, 2019
Page 2
      Protein and Speciality reporting units comprised separate operating
segments in prior
      years, please advise how those units met the aggregation criteria in ASC
280-10-50-11 in
      prior years. In any event, please ensure your financial statements
clearly disclose your
      identified operating segments as distinguished from your reporting units
and consider
      discussing your results of operations on an operating segment basis, if
appropriate.
      Finally, please provide the history of your determination of operating
and reportable
      segments from the point you became a reporting company to the most recent
annual
      financial statements. We may have further comment.
        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 Yolanda Guobadia, Staff Accountant, at (202) 551-3562 or
Jim
Allegretto, Senior Assistant Chief Accountant, at (202) 551-3849 with any
questions.



                                                          Sincerely,
FirstName LastNameChristopher Pappas
                                                          Division of
Corporation Finance
Comapany NameThe Chefs' Warehouse, Inc.
                                                          Office of Consumer
Products
September 23, 2019 Page 2
cc:       Alexandros Aldous
FirstName LastName