July 29, 2019

Elisa D. Garcia
Executive Vice President, Chief Legal Officer and Secretary
Macy's, Inc.
7 West Seventh Street
Cincinnati, Ohio 45202

       Re: Macy's, Inc.
           Form 10-K for the Fiscal Year Ended February 2, 2019
           Filed April 3, 2019
           File No. 001-13536

Dear Ms. Garcia:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended February 2, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 21

1.    Please quantify for us the amount of bluemercury and gift card breakage
revenues
      recorded within your statements of income for the periods presented. To
the extent that
      these items have and/or are expected to materially impact your statements
of operations,
      ensure you adequately discuss such trends and impacts within MD&A. For
example,
      please supplement your disclosures if bluemercury is disproportionately
contributing to
      your comparable sales movements or its sales are not moving in tandem
with the sales
      trends of your other branded stores.
 Elisa D. Garcia
FirstName LastNameElisa D. Garcia
Macy's, Inc.
Comapany NameMacy's, Inc.
July 29, 2019
July 29, 2019 Page 2
Page 2
FirstName LastName
Important Information Regarding Non-GAAP Financial Measures, page 29

2.       We note that your presentation on page 32 of "Adjusted EBITDA," when
used as the
         numerator to your ROIC calculation, differs from your "Adjusted
EBITDA" figure
         presented elsewhere in your filing, including on page 31. Since the
presentation on page
         32 excludes rent expense, please consider labeling this measure as
"Adjusted EBITDA,
         excluding rent expense," or a similar name, to convey to your readers
that these are, in
         fact, different measures.
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Critical Accounting Policies, page 33

3.       We note that your common stock price and your overall market
capitalization have
         significantly declined since the completion of your annual goodwill
impairment test at the
         end of May 2018. Since a decline in market capitalization may be
indicative of a potential
         goodwill impairment and goodwill is material to your financial
statements, please include
         a goodwill impairment critical accounting policy in future filings or
advise us why you
         believe goodwill impairment does not represent a critical accounting
policy. We believe
         critical accounting policy disclosures should include, but not be
limited to, a discussion of
         the significant decline in your market capitalization and how that
impacted your goodwill
         impairment assessment. Also, to the extent you performed step one of
your goodwill
         impairment test and any of your reporting units are at risk of failing
step one of the test,
         please also disclose:

             The percentage by which fair value exceeded carrying value as of
the date of the most
             recent test;
             The amount of goodwill allocated to the reporting unit;
             A description of the methods and key assumptions used and how the
key assumptions
             were determined;
             A discussion of the degree of uncertainty associated with the key
assumptions; and
             A description of potential events and/or changes in circumstances
that could
             reasonably be expected to negatively affect the key assumptions.

         Please note that a reporting unit may be at risk of failing step one
of the impairment test if
         it had a fair value that is not substantially in excess of carrying
value as of the date of the
         last impairment test.
 Elisa D. Garcia
Macy's, Inc.
July 29, 2019
Page 3




        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.

       You may contact Yong Kim, Staff Accountant, at 202-551-3323 or Andrew
Blume, Staff
Accountant, at 202-551-3254 if you have questions regarding comments on the
financial
statements and related matters. Please contact Jennifer Thompson, Accounting
Branch Chief, at
202-551-3737 with any other questions.



FirstName LastNameElisa D. Garcia                         Sincerely,
Comapany NameMacy's, Inc.
                                                          Division of
Corporation Finance
July 29, 2019 Page 3                                      Office of Consumer
Products
FirstName LastName