May 27,
2010
United
States
Securities
and Exchange Commission
Division
of Corporation Finance
100 F
Street, N.E.
Washington,
D.C. 20549
Attn: H.
Roger Schwall
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Re:
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J
& J Snack Foods Corp.
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Form
10-K for the Fiscal Year Ended September 26, 2009
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Filed
December 8, 2009
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Form
10-Q for the Fiscal Quarter Ended December 26, 2009
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Filed
January 21, 2010
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Response
Letter Dated May 5, 2010
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File
No. 0-14616
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Dear Mr.
Schwall:
This is in response to your letter
dated May 5, 2010. Our responses are keyed to your
comments.
Form 10-K for the Fiscal
Year Ended September 26, 2009
Note O – Segment Reporting,
page F-23
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1.
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We
have considered your response to comment 3 in our letter dated April 23,
2010, whereby you have stated that you do not believe that information
about your products is necessary as you have concluded that all of your
products are snack foods and are therefore, similar in
nature. However, we are unable to agree with our
conclusions. Based on the information in your filing, including
your President’s letter to your shareholders, it appears that you sell
products to variious segments within the food industry, including snack
foods, frozen beverages, desserts and bakery
products. Therefore, for each period reported, please disclose
total revenues for each of your primary products pursuant to FASB ASC
Topic 280-10-50-40. Based on your disclosure on pages 2 and 3
of your filing, your primary products appear to be, Soft Pretzels, Frozen
Juice Treats and Desserts, Churros, Bakery Products and Frozen
Beverages. We will not object to your complying with this
comment on a prospective basis beginning with your next Form
10-Q.
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Company
Response:
We
will comply with this comment on a prospective basis beginning with our next
Form 10-Q.
Please
review our response and contact me if you have any further questions or
comments.
Very
truly yours,
/s/ Dennis G.
Moore
Dennis G.
Moore
Senior
Vice President and Chief Financial Officer