July 2, 2010
VIA EDGAR AND BY FACSIMILE
United States Securities and Exchange Commission
Division of Corporation Finance
Mailstop 3561
100 F Street, N.E.
Washington, D.C. 20549
Attn: Tia Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel and
Healthcare Services
Re: Guess?, Inc.
Form 10-K for fiscal year ended January 30, 2010
Filed March 31, 2010
File No. 001-11893
Dear Ms. Jenkins,
On behalf of Guess?, Inc (the “Company”), this letter sets forth the Company’s response to the comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in your letter dated June 25, 2010, following up on the Company’s response letter dated June 4, 2010, regarding the Company’s above-referenced Form 10-K (the “Form 10-K”). For your convenience, the Staff’s comment precedes the response.
Form 10-K for Fiscal Year Ended January 30, 2010
Note (1) Summary of Significant Accounting Policies and Procedures, page F-7
1. Please tell us and disclose in future filings, to the extent material, how you reflect any changes in the carrying amount redeemable of noncontrolling interests within your computation of earnings per share.
Securities and Exchange Commission
July 2, 2010
Response:
EITF Topic D-98 paragraph 19 requires that when a class of common stock is redeemable at other than fair value, increases or decreases in the carrying amount of the redeemable security should be reflected in earnings per share through the application of the two-class method. Periodic adjustments to the carrying amount that reflect a redemption in excess of fair value are applied to earnings per share using the two-class method while decreases in the security’s carrying amount are applied to earnings per share using the two-class method only to the extent they represent recoveries of amounts previously applied to the two-class method.
Our computation of earnings per share has not been impacted to date as we have not experienced a situation where the redemption value of either of our existing put arrangements exceeded their fair value. However, should this situation arise, to the extent that it has a material impact on earnings per share, we undertake to disclose in our quarterly and annual filings how we reflect any changes in the carrying amount of redeemable noncontrolling interests within our computation of earnings per share.
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We appreciate the Staff’s comments and request that the Staff contact the undersigned at (213) 765-3630 or (213) 765-0911 (facsimile) with any questions or comments regarding this letter.
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Very truly yours, |
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/s/ Jason T. Miller |
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Jason T. Miller |
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Assistant General Counsel |
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Guess?, Inc. |
cc:
Brian McAllister
Accounting Examiner
U.S. Securities and Exchange Commission
Dennis R. Secor
Senior Vice President and Chief Financial Officer
Guess?, Inc.