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We note that in Fiscal 2013, you began to present your comparable store sales change as a single, consolidated metric including your Ralph Lauren stores, factory stores, club Monaco stores, and e-commerce sites. We also note “e-commerce will remain a critical area of focus and investment for [you] over the next several years.” To enhance an investor's understanding of your sales trends and potential variability, in future filings please confirm that in future filings you will present comparable store sales in a manner that separately quantifies e-commerce (e.g. comparable store sales percentage change excluding e-commerce sales) and appropriately discuss the impact of such changes on your operations. Please provide us with draft disclosure to be included in future filings.

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Our customers expect to be able to purchase merchandise in the same assortment and for the same price, regardless of whether the purchase is made in one of our physical stores or through our e-commerce websites. Our retail customer experience objective is that a customer will receive the same quality of product and consistent brand experience regardless of shopping method. For example, we have found that our customers may research an apparel product online and then come to the store to inspect and try on the apparel. The customer may then purchase in the store from store stock, or purchase later online. Even if a customer is in one of our physical stores, the salesperson has the ability to use a computer or tablet to broaden the customer's shopping experience by allowing the customer to view additional styles or sizes of products and to purchase from our website while in the store.

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While we do sell a broad array of brands and products at various price points, our objective is that a customer will generally find online substantially all of the same merchandise as the customer would find in our physical stores. This is an important factor for successful omni-channel retailers. In addition, although we may have some differences in assortment for each retail store (due to store size, demographics, or format), our physical stores have the ability to sell our online merchandise directly to their customer.

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Our retail channel operates from a shared stock of inventory. For example, if we cannot fulfill an order in one of our physical stores because we are out of stock at that location, we will ship that product to our customer as if it were an online sale. Conversely, if we make a sale online that is out of stock, we will fulfill that order through inventory that is held at and shipped from one of our physical stores. Even more broadly, we allow our customers to shop online within our stores so that they can access our full brand portfolio, which may not otherwise be carried by a specific store location. Our customers may also return items that are purchased online to one of our physical stores.

•	We attempt to harmonize our initial prices between our physical stores and our e-commerce sites within a specific geography. We also aim to align promotions and markdowns in terms of both discount and duration.

•	We employ consistent and centralized marketing and advertising themes and strategies across our entire retail channel. Our goal is to present to the customer a consistent message of our brands and products, regardless of whether they are in one of our physical stores or are shopping via one of our e-commerce sites.

•	The merchandise we sell across our retail channel is sourced as a consolidated purchase order for our physical stores and e-commerce sites. The transportation between our production points and distribution hubs is not dependent on whether the product is sold directly to a customer online or through one of our physical retail stores.

•	We sell gift cards to our customers both online and in our physical stores. Regardless of how they are purchased, these gift cards are honored by our entire retail channel, and are not specific to online or physical store purchases.

•	The customer information we gather across all retail channels within our predominant geographic region is consolidated into a single database for a comprehensive, omni-channel record of customer information and purchase history. As a result, regardless of whether a customer interacts with our brand in person

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We have been upgrading our systems and processes to allow our entire retail operation to develop a holistic view of our customer so that we can satisfy our customer's demand for any product category at any time, regardless of purchase method. This includes investing in systems that permit us to have real time inventory and customer information, updating our point of sales registers within our physical stores, developing tablet applications that allow our salesperson to understand and satisfy customer demand, and incorporating our omni-channel sales strategy into our training of in-store sales associates.

•	the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•	Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to filing; and

•	the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.