August 5, 2019

Michelle Gass
Chief Executive Officer
KOHLS Corp
N56 W17000 Ridgewood Drive
Menomonee Falls, Wisconsin 53051

       Re: KOHLS Corp
           Form 10-K for Fiscal Year Ended February 2, 2019
           Filed March 22, 2019
           File No. 001-11084

Dear Ms. Gass:

      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 this 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.

Annual Report on Form 10-K for the fiscal year ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Net Sales, page 19

1.    We note your statement on page 19 that as an omnichannel retailer, it is
often difficult for
      you to distinguish between a store sale and a digital sale, and therefore
you do not report
      store sales and digital sales separately. However, we note statements in
your fourth
      quarter 2018 earnings call and your first quarter 2019 earnings calls
which suggest that
      you are able to track digital sales separately. Specifically, your Chief
Financial
      Officer stated in your fourth quarter 2018 earnings call that "[t]he
strong sales
      performance was driven by positive transactions and a double-digit
increase in digital
      sales, which was on top of the 26% increase in the fourth quarter of last
year" and your
      Chief Executive Officer elaborated on why this increase in digital sales
occurred during
      her update on your omnichannel strategies. Similarly, your Chief
Financial Officer stated
      in your first quarter 2019 earnings call that "[d]igital sales remained
solid in Q1 growing
 Michelle Gass
KOHLS Corp
August 5, 2019
Page 2
         high single-digits, which was on top of the mid-teens percent increase
in the prior year.
         The solid results reflect the positive impact that our investments are
having on customer
         engagement. Mobile again represented the majority of our traffic
growth at over 75% of
         digital traffic and more than half of digital sales." Please tell us
why you appear to be able
         to distinguish between store and digital sales in your earnings calls
and why you
         separately discuss digital sales in your earnings calls. Please
reconcile this discussion
         during your earnings calls with the disclosures in your Form 10-K that
you do not have a
         clear distinction between store and digital sales. Also tell us why
your analysis of results
         of operations does not quantify net sales from your digital channel
and does not disclose
         information about the increase in digital sales and the drivers of
that increase similar to the
         information currently provided during your earnings calls. We may have
further comment
         after reviewing your response.


        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 Sondra Snyder, Staff Accountant at (202) 551-3332,
Jennifer
Thompson, Accounting Branch Chief at (202) 551-3737, Danilo Castelli, Staff
Attorney at (202)
551-6521 or Jacqueline Kaufman, Staff Attorney at (202) 551-3797 with any
questions.



FirstName LastNameMichelle Gass                                 Sincerely,
Comapany NameKOHLS Corp
                                                                Division of
Corporation Finance
August 5, 2019 Page 2                                           Office of
Consumer Products
FirstName LastName