May 25, 2010

 

VIA EDGAR

 

United States Securities and Exchange Commission

Division of Corporation Finance

Mailstop 3561

100 F Street, N.E.

Washington, D.C. 20549-4561

Attn:       John Reynolds

                                                Assistant Director

 

Re:

Guess?, Inc.

 

Form 10-K for fiscal year ended January 30, 2010

 

Filed March 31, 2010

 

File No. 001-11893

 

Dear Mr. Reynolds:

 

Guess?, Inc. (the “Company”) is in receipt of your letter dated May 13, 2010 (the “Comment Letter”) that sets forth the comments of the staff of the Securities and Exchange Commission (the “Commission”) regarding the Company’s above-referenced Form 10-K.  In the Comment Letter, you requested that the Company respond to the comments set forth in the Comment Letter within 10 business days of May 13, 2010, or tell the Commission when the Company would provide a response.

 

The Company is in the process of preparing a response to the Comment Letter and plans to provide that response to the Commission on or before June 4, 2010.  The Company is scheduled to publicly release its first quarter earnings results on May 27, 2010 and the additional time to file the response is required to facilitate the completion of a thorough response after the conclusion of the earnings release process.

 

 

Very truly yours,

 

 

 

/s/ Jason T. Miller

 

Jason T. Miller

 

Assistant General Counsel

 

Guess?, Inc.

 

(213) 765-3630 (direct)

 

(213) 765-0911 (facsimile)

 

 

cc:

Dennis R. Secor

 

 

Senior Vice President and Chief Financial Officer

 

 

Guess?, Inc.