Mail Stop 3-8


								May 17, 2005


By Facsimile and U.S. Mail

Mr. Walker Boyd
Group Financial Director
Signet Group plc
Zenith House
The Hyde
London, England  NW9 6EW

		RE:	Signet Group plc
			Form 20-F for the year ended January 29, 2005
			Filed May 3, 2004

Dear Mr. Boyd:

	We have reviewed your filing and have the following comments.
Where indicated, we think you should revise your documents in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


FORM 20-F FOR THE YEAR ENDED JANUARY 29, 2005

Note 31.  Summary of differences between UK and US generally
accepted
accounting principles, page 103
Goodwill, page 103

1. You state that you perform annual impairment reviews on
goodwill
under US GAAP by comparing the carrying amount of goodwill to its
fair value on an undiscounted basis.  Please clarify for us how
your
US GAAP goodwill impairment policy complies with paragraphs 18-31
of
SFAS No. 142, which require that goodwill be tested for impairment
at
the reporting unit level using a two-step test.  In particular, we
do
not understand how the use of undiscounted cash flows is
consistent
with the objective of measuring fair value, as discussed in
paragraph
24 of SFAS No. 142.  If your accounting complies with these
paragraphs, please revise your disclosures in future filings to
clarify how you comply with the impairment test required by SFAS
No.
142.  If not, please quantify for us the effect on your US GAAP
net
income and shareholders` funds if you had tested for goodwill
impairment pursuant to SFAS No. 142.


   As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please provide us with a supplemental response letter that keys
your
responses to our comments and provide any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your responses to our
comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in their filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the 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.

		In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.

	If you have any questions regarding these comments, please
direct them to Nili Shah at (202) 942-2923.  Any other questions
regarding disclosure issues may be directed to me at (202) 551-
3841.

							Sincerely,



							Mike Moran
							Accounting Branch Chief

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Mr. Walker Boyd
Group Financial Director
Signet Group plc
May 17, 2005
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