February 27, 2019

Charles V. Bergh
President and Chief Executive Officer
LEVI STRAUSS & CO
1155 Battery Street
San Francisco, CA 94111

       Re: LEVI STRAUSS & CO
           Registration Statement on Form S-1
           Filed February 13, 2019
           File No. 333-229630

Dear Mr. Bergh:

       We have reviewed your registration statement 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form S-1 filed February 13, 2019

Executive Compensation
Base Salary, page 124

1.     Please add the disclosure regarding the factors you consider in
determining base salary
       that you indicated you would include in your December 6, 2018 response
to prior
       comment 3.
Choice of Forum, page 166

2.     We note that your forum selection provision identifies the Court of
Chancery of the State
       of Delaware as the exclusive forum for certain litigation, including any
"derivative
       action." Please disclose whether this provision applies solely to state
law claims. If it does
       not apply to solely state law claims, then we note that Section 22 of
the Securities Act
 Charles V. Bergh
LEVI STRAUSS & CO
February 27, 2019
Page 2
      creates concurrent jurisdiction for federal and state courts over all
suits brought to enforce
      any duty or liability created by the Securities Act or the rules and
regulations thereunder.
      If this provision applies to claims arising under the Securities Act,
please disclose that
      there is uncertainty as to whether a court would enforce such provision
and to state that
      shareholders will not be deemed to have waived the company's compliance
with the
      federal securities laws and the rules and regulations thereunder.
General

3.    We note that you have updated certain disclosures to November 25, 2018.
Please update
      your disclosures to the most recent practicable date, as requested in our
prior comment 2.
      We note, as examples, the shares outstanding on pages 11 and 167,
management
      disclosure on page 112 and properties on page 110.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact James Giugliano at 202-551-3319 or Raj Rajan, Senior
Accountant, at
202-551-3388 if you have questions regarding comments on the financial
statements and related
matters. Please contact Ruairi Regan at 202-551-3269 or Pam Howell at
202-551-3357 with any
other questions.



                                                             Sincerely,

FirstName LastNameCharles V. Bergh                           Division of
Corporation Finance
                                                             Office of
Beverages, Apparel and
Comapany NameLEVI STRAUSS & CO
                                                             Mining
February 27, 2019 Page 2
cc:       Eric C. Jensen, Esq.
FirstName LastName