SecProbe.io

May 10, 2011
 Via E-mail

Mr. John G. Call, Senior Vice Pres ident and Chief Financial Officer
Ross Stores, Inc. 4440 Rosewood Drive
Pleasanton, California 94588

Re: Ross Stores, Inc.
 Form 10-K for Fiscal Year End January 29, 2011
Filed March 29, 2011 File No. 000-14678

Dear Mr. Call:
 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 apply to your fact s 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 ma y have additional comments.
 Form 10-K for Fiscal Year End January 29, 2011

 Market for Registrant’s  Common Equity, Related Stockholder Matters and Issuer Purchases of
Equity Securities, page 14

1. Please confirm that in future filings, you w ill provide the information required by Item
201(a)(1)(ii) of Regulation S-K.

John G. Call Ross Stores, Inc. May 10, 2011 Page 2

 Management’s Discussion and Analysis of Financ ial Condition and Results of Operations, page
18

2. We note the reference to “packaway inventory”  on page 22 and statements regarding the
cash provided by, and replenishment of, your me rchandise inventory.  We also note the
description of packaway on page four as a pproximately half of your inventory, which is
merchandise purchased “with the intent that it will be stored in our  warehouses until a
later date.”  Please revise your Management’s Discussion and Analysis in future filings to
clarify in quantitative and qua litative terms the turnover of  your packaway inventory, the
effect upon liquidity of the delayed tur nover of packaway inventory, and any known
trends, events or uncertainties with respect to it.   See It em 303(a)(1) of Regulation S-K
and Instructions 1 and 2 to Item 303( a).  Please provide draft disclosure.
 Financial Statements

Notes to Financial Statements
Note A: Summary of Significant Accounting Policies
Revenue, page 35

3. It appears from your disclosure that revenue from the sale of gift cards is deferred until
redeemed for a purchase. Please provide us w ith and confirm that in future filings you
will revise to clarify your policy as it relates to gift cards th at are never redeemed or not
redeemed over an extended period of time.  Please ensure your response addresses when
and if your gift cards expire and when the li ability for unredeemed gift cards is removed
from the balance sheet.
 Item 9A – Controls and Procedures

Disclosure Controls and Procedures, page 53

4. We note your statement that “any system of controls, however well designed and
operated, can provide only reasonable, and not absolute, assurance that the objectives of
the system will be met”.  Please provide us with and confirm that in future filings you will revise your disclosure to state clearly, if true, that your disclosure controls and
procedures are designed to  provide reasonable assurance of  achieving their objectives and
that your principal executive o fficer and principal financial officer concluded that your
disclosure controls and procedur es are effective at that reason able assurance level.  In the
alternative, remove the reference to the level of assurance of your disclosure controls and
procedures.
 Exhibits

5. We note exhibit 10.14 appears to be missing atta chments, exhibits or appendices.  Please
confirm that you will file the exhibit in its  entirety with your next periodic report
pursuant to Item 601(b)(10) of Regulation S-K.

John G. Call Ross Stores, Inc. May 10, 2011 Page 3

 We urge all persons who are responsible for th e accuracy and adequacy 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 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 federa l securities laws of  the United States.

You may contact Angela Halac at (202) 551-3398 or Brian Bh andari at (202) 551-3390 if
you have questions regarding comments on the fina ncial statements and related matters.  Please
contact Erin Wilson at (202) 551-6047 or Ja mes Lopez at (202) 551-3536 with any other
questions.
Sincerely,

 /s/ James Lopez (for)
   John Reynolds
Assistant Director