SecProbe.io

April 11, 2012

Via E-mail
Eric C. Wiseman Chief Executive Officer V.F. Corporation 105 Corporate Center Boulevard Greensboro, NC 27408
 Re: V. F. Corporation
  Form 10-K for the Year Ended December 31, 2011
Filed February 29, 2012
  File No. 001-5256

 Dear Mr. Wiseman:
We have reviewed your filing 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 within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response. If you do not believe our comments a pply to your facts and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.  Form 10-K for the Year Ended December 31, 2011

 Management’s Discussion and Analysis of Financ ial Condition and Results of Operations, page
29
 Non-GAAP Financial Information, page 51

 1. It appears that you have pres ented an alternative income statement which excludes the
impact of the 2011 Timberland acquisition a nd the impact of 2010 impairment charges
that were recorded in your GAAP-basis Statem ent of Income. This appears to represent a
full non-GAAP income statement which puts undue prominence on the Non GAAP measures.  Please confirm in future Exchange Act filings you will remove such presentation or tell us why you believe it ap propriate. For additional guidance, refer to

Eric C. Wiseman V.F. Corporation April 11, 2012 Page 2

 Question 102.10 of the Compliance & Disclosu re Interpretations regarding Non-GAAP
Financial Measures.
  Closing Comments

   We urge all persons who are responsible fo r the accuracy and adequ acy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. 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 provi de a written statement from the company
acknowledging that:   the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in re sponse to staff comments do not foreclose the
Commission from taking any action w ith 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 Craig Arakaw a at (202) 551-3650 or Meli ssa Rocha at (202) 551-3854,
if you have questions regarding comments on the financial statements and related matters.
Please contact me at (202) 551-3871 with any other questions.          S i n c e r e l y ,           / s / T i a  L .  J e n k i n s           T i a  L .  J e n k i n s          Senior Assistant Chief Accountant         Office of Beverages, Apparel and
Mining