July 18, 2019
Via E-mail
Sandeep Reddy
Chief Financial Officer
Guess, Inc.
1444 South Alameda Street
Los Angeles, CA 90021

       Re:     Guess, Inc.
               Form 10-K for the Fiscal Year Ended February 2, 2019
               Filed March 29, 2019
               File No. 1-11893

Dear Mr. Reddy:

        We have limited our review of your filing to your contacts with
countries that have been
identified as state sponsors of terrorism, and we have the following comments.
Our review with
respect to this issue does not preclude further review by the Assistant
Director group with respect
to other issues. In our comments, we 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.

General

   1. In your letter to us dated July 14, 2015, you discussed contacts with
Syria and Sudan.
      Guess Watches' website identifies Allied Business Co. in Damascus, Syria
in the Global
      Contacts section. As you know, Syria and Sudan are designated by the
State Department
      as state sponsors of terrorism and are subject to U.S. sanctions and/or
export controls.
      Your Form 10-K does not provide disclosure about those countries. Please
describe to us
      the nature and extent of any past, current, and anticipated contacts with
Syria and Sudan
      since the 2015 letter, including contacts with their governments, whether
through
      subsidiaries, licensees, distributors, affiliates, or other direct or
indirect arrangements.

   2. Please also discuss the materiality of those contacts, in quantitative
terms and in terms of
      qualitative factors that a reasonable investor would deem important in
making an
      investment decision. Tell us the approximate dollar amounts of any
revenues, assets and
      liabilities associated with Syria and Sudan for the last three fiscal
years and the
 Sandeep Reddy
Guess, Inc.
July 18, 2019
Page 2

         subsequent interim period. Address for us the potential impact of the
investor sentiment
         evidenced by divestment and similar initiatives that have been
directed toward companies
         that have operations associated with U.S.-designated state sponsors of
terrorism.

         We urge all persons who are responsible for the accuracy and adequacy
of the disclosure
in the filing to be certain that the filing includes the information the
Securities Exchange Act of
1934 and all applicable Exchange Act rules require. 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 responding to our comments, please provide a written statement from
the company
acknowledging that:

         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 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.

        You may contact Jennifer Hardy, Special Counsel, at (202) 551-3767 or
me at (202) 551-
3470 if you have any questions about the comments or our review.

                                                             Sincerely,

                                                             /s/ Cecilia Blye

                                                             Cecilia Blye,
Chief
                                                             Office of Global
Security Risk

cc:      John Reynolds
         Assistant Director