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CORRESP

 May 6, 2019

 VIA EDGAR

 Securities and Exchange Commission

Division of Corporation Finance

 Office of
Consumer Products

 100 F Street, NE

Washington, DC 20549

Attention:
 Tony Watson, Accountant
Donna Di Silvio, Accountant

Re:
 Williams-Sonoma, Inc.
Form 8-K filed March 20, 2019
File No. 001-14077

 Ladies and Gentlemen:

Williams-Sonoma, Inc. (the “Company”) is submitting this letter in response to the comment letter dated April 30, 2019
(the “Comment Letter”) from the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) regarding the Staff’s review of the Company’s Form 8-K filed March 20, 2019.

 For your convenience, the Staff’s comment has been
repeated below in its entirety, with the Company’s response set out immediately underneath it. The heading and numbered response in this response letter correspond to the heading and numbered comment contained in the Comment Letter.

Form 8-K filed March 20, 2019

 Non-GAAP Reconciliations, page 8

1.
 Please tell us your consideration of the guidance in the answer to Question 102.10 of the Non-GAAP
Financial Measures section of our Compliance Disclosure and Interpretations related to your presentation of full non-GAAP income statements.

Response: In response to the Staff’s comment, the Company respectfully advises the Staff that it had not previously considered
the non-GAAP reconciliations on page 8 to be a full non-GAAP income statement, as the reconciliations do not include certain line items from the Company’s GAAP
income statement. However, the Company acknowledges the Staff’s comment and will revise its disclosure accordingly going forward to ensure that future non-GAAP reconciliations in the Company’s
earnings releases do not constitute a full non-GAAP income statement. Attached please find an example of how the Company intends to present future non-GAAP
reconciliations, using Q4 2018 numbers for illustrative purposes.

 Securities and Exchange Commission

Attn:
 Tony Watson, Accountant
Donna Di Silvio, Accountant

 May 6, 2019

  Page
 2

 Should the Staff have any additional comments or questions, please contact me at (415) 616-8524 or David King at (415) 616-8478. The Company respectfully requests that the Staff confirm that it has no additional requests or comments when the Staff’s review
is complete.

 Sincerely,

/s/ Julie Whalen

 Julie Whalen

 Executive Vice President,

Chief Financial Officer

cc:
 David King – Executive Vice President, General Counsel and Secretary

Brett Cooper – Orrick, Herrington & Sutcliffe LLP

 Attachment

 -2-

 Exhibit 1

 4th Quarter GAAP to Non-GAAP Reconciliation (unaudited)

 Fourteen Weeks
Ended February 3, 2019

 (Dollars in thousands, except per share data)

$

% of revenues

  Selling, general and administrative expenses

$
509,070

27.7%

 Outward-related1

(6,918
)

 Employment-related expense2

(2,543
)

 Tax legislation3

(269
)

 Impairment and early termination charges4

(5,995
)

 Non-GAAP selling, general and administrative expenses

$
493,345

26.9%

$

% of revenues

  Operating income

$
    200,853

10.9%

 Outward-related1

7,242

 Employment-related expense2

2,543

 Tax legislation3

269

 Impairment and early termination charges4

6,762

 Non-GAAP operating income

$
217,669

11.9%

$

Tax rate

  Income taxes

$
43,882

22.0%

 Outward-related1

846

 Employment-related expense2

584

 Tax legislation3

(254
)

 Impairment and early termination charges4

1,588

 Non-GAAP income taxes

$
46,646

21.6%

$

  Diluted EPS

$
 1.93

 Outward-related1

0.08

 Employment-related expense2

0.02

 Tax legislation3

0.01

 Impairment and early termination charges4

0.06

 Non-GAAP Diluted EPS*

$
 2.10

 * Per share amounts may not sum due to rounding to the nearest cent per diluted share

 Notes to Exhibit 1:

1      During Q4 18 we incurred approximately $7.2 million of expense, primarily associated with acquisition-related
compensation expense, amortization of intangible assets, as well as the operations of Outward, Inc, of which $6.9 million was recorded within selling, general and administrative expenses.

 2       During Q4 18 we
incurred approximately $2.5 million of employment-related expense primarily associated with a one-time special equity grant, which was recorded within selling, general and administrative expenses.

 3       During Q4 18, we
incurred approximately $0.3 million in expenses associated with tax legislation changes, which was recorded within selling, general and administrative expenses.

 4       During Q4 18, we
incurred approximately $6.8 million of expense, primarily associated with store impairment and early lease termination charges, of which $6.0 million was recorded within selling, general and administrative expenses.