In this paper I investigate thanks responses from a variationist perspective. Although both their form and frequency have been said to differ according to both the variety of English and the formality of the situation (cf. Farenkia, 2012; Schneider, 2005; Aijmer, 1996; Leech and Svartvik, 1994; Edmondson and House, 1981), this variation has yet to be quantified through the analysis of naturally occurring speech. I analyze variation along the socio-economic scale in Los Angeles, California in both the form and frequency of verbal thanks responses and whether the type of favor affects the form or frequency of thanks responses. In order to do this, I take a function-to-form perspective to analyze discourse from restaurant service encounters in nine restaurants of three different price ranges. The results of this study show that there is variation in the frequency and use of thanks responses. Forms of you’re welcome are only used in the more formal and expensive restaurants, never in the informal and inexpensive ones. Additionally, verbal thanks responses are found 50 percent more frequently in the expensive restaurants than in the inexpensive ones. Finally the type of favor that most frequently receives a verbal thanks response does differ among the three price ranges of restaurants.