-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, KHLJJg3Nh//KDkcMCG91IOyrpxFhMZnXMR4XM8yOTjHupjJXJw6P3R5n0NEwtJWy iOr/B9PjmswygpyXi2pwtQ== 0001104659-07-024316.txt : 20070718 0001104659-07-024316.hdr.sgml : 20070718 20070330163558 ACCESSION NUMBER: 0001104659-07-024316 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20070330 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GUESS INC CENTRAL INDEX KEY: 0000912463 STANDARD INDUSTRIAL CLASSIFICATION: WOMEN'S, MISSES', CHILDREN'S & INFANTS' UNDERGARMENTS [2340] IRS NUMBER: 953679695 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ATTN: ANGELINA ORONA STREET 2: 1444 SOUTH ALAMEDA STREET CITY: LOS ANGELES STATE: CA ZIP: 90021 BUSINESS PHONE: (213) 765-3100 MAIL ADDRESS: STREET 1: ATTN: ANGELINA ORONA STREET 2: 1444 SOUTH ALAMEDA STREET CITY: LOS ANGELES STATE: CA ZIP: 90021 FORMER COMPANY: FORMER CONFORMED NAME: GUESS INC ET AL/CA/ DATE OF NAME CHANGE: 19940902 CORRESP 1 filename1.htm

[GUESS?, INC. LOGO]

March 30, 2007

Michael Moran
Branch Chief
Mail Stop 3561
US Securities and Exchange Commission
Washington, D.C. 20549

Re:                             Guess?, Inc.
Item 4.01 Form 8-K
Filed March 23, 2007
File No. 1-11893

Dear Mr. Moran,

On behalf of Guess?, Inc (the “Company”), I am responding to the comment letter dated March 26, 2007 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), with respect to the above-referenced Form 8-K. Set forth below is the Staff’s comment and the Company’s response thereto.

Staff Comment

1.                                      It appears the circumstances you describe in your filing represents a future dismissal of your independent accountants. Please note that you are required to file an amended Form 8-K when KPMG has completed all audit work with respect to the period ended February 3, 2007. We would expect you to disclose the date they completed all audit work, and to be able to state, if true, that there were still no disagreements or reportable events through this date.  The amendment should include another letter from KPMG confirming that they agree with the updated disclosures, if true. Please acknowledge this obligation to file the Form 8-K amendment.

Company Response

The Company acknowledges its obligation to file, and intends to file, a Form 8-K amendment upon completion by KPMG of all audit work with respect to the period ended February 3, 2007 as described in Staff Comment Number 1 above.

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In connection with the above comment and our response, we would also like to acknowledge our understanding that the Company is responsible for the adequacy and accuracy of the disclosures in our filings; that 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 that 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.

We believe that this response addresses your comment. If you have any further questions, please do not hesitate to call me directly at (213) 765-3630.

Very truly yours,

 

 

 

/s/ Jason T. Miller

 

Jason T. Miller

 

Assistant General Counsel

 

Guess?, Inc.

 

cc:                                 Carlos Alberini, President and COO
Dennis Secor, Senior Vice President and CFO

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