August 9, 2019
Jane Hamilton Nielsen
Chief Operating Officer and Chief Financial Officer
Ralph Lauren Corporation
650 Madison Avenue
New York, NY 10022
Re: Ralph Lauren Corporation
Form 10-K for the Fiscal Year Ended March 30, 2019
Filed May 16, 2019
File No. 001-13057
Dear Ms. Hamilton Nielsen:
We have reviewed your filing and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your
disclosure.
Please respond to the 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 the Fiscal Year Ended March 30, 2019
Notes to Consolidated Financial Statements
Note 9. Restructuring and Other Charges
Way Forward Plan, page F-26
1. We note in connection with the Way Forward Plan, on March 30, 2017, your
Board of
Directors approved the closure of your Polo store in New York City. You
disclose that
this location is no longer generating revenue and has no other economic
activity. We also
note that this appears to be a "build-to-suit" lease which has been
capitalized. Please
provide us with your impairment analysis of this leased asset, including
your assumptions
used to determine fair value.
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.
Jane Hamilton Nielsen
Ralph Lauren Corporation
August 9, 2019
Page 2
You may contact Joel Parker at 202-551-3651 with any questions.
Sincerely,
FirstName LastNameJane Hamilton Nielsen
Division of
Corporation Finance
Comapany NameRalph Lauren Corporation
Office of Beverages,
Apparel and
August 9, 2019 Page 2 Mining
FirstName LastName