SecProbe.io

June 15, 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.
 May 18, 2011 Supplemental Response to
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 supplemental respons e to our letter dated May 10, 2011 and have
the following comments.  In some of our co mments, 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

Supplemental Response, submitted May 18, 2011
 Management’s Discussion and Analysis of Financ ial Condition and Results of Operations, page
18

1. We note your response to comment 2 of our letter dated May 11, 2011.  Please revise
future filings to further clarify the reasons for material trends in packaway inventory and identify the principal factors you consider wh en determining to use packaway inventory
instead of other inventory.   Also, please cl arify the term “a semi-annual selling season.”
Please provide revised draft disclosure.

John G. Call Ross Stores, Inc. June 15, 2011 Page 2

 Financial Statements

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

2. We reviewed your response to our prior comm ent 3.  Please tell us why you believe it is
appropriate to record gift card breakage as  a reduction of operating expenses versus
revenue or other operating income.  In addition, for each period presented, provide us with the amount of breakage recognized a nd the amount of your unredeemed gift card
liability.
 Item 9A – Controls and Procedures

Disclosure Controls and Procedures, page 53

3. We have reviewed your response to our prio r comment 4.  Your response did not address
our comment, thus the comment will be re issued.  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 disclosu re 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 officer and
principal financial officer concluded  that your disclosure cont rols and procedures are
effective at that reasonable assurance level .  In the alternative, remove the reference to
the level of assurance of your disclo sure controls and procedures.

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.
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