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August 15, 2005

Mr. Adam Phippen and Ms. Robyn Manuel
Staff Accountant
Securities and Exchange Commission
Washington, D.C.  20549

Re:  Harold's Stores, Inc. - Commission File No. 1-10892

Dear Mr. Phippen and Ms. Manuel:

Based on further discussions with you on August 10,
2005, we would like to revise our responses to Item 4
and Item 5 of your comment letter dated July 7, 2005 as
follows:

Form 10-K for Fiscal Year Ended January 29, 2005

Item 7. Management's Discussion and Analysis of
Financial Condition and Results of Operations

     Liquidity
     4.   Comment:  Please refer to Item 10(e) of Regulation
       S-K as well as our Frequently Asked Questions Regarding
       the Use of Non-GAAP Financial Measures (available on our
       website at www.sec.gov) and provide us in detail your
       justification for presenting in footnote (1) to the
       table various measures of your liquidity as if your line
       of credit was classified as long-term.  We believe each
       of these measures represents a non-GAAP measure since
       under GAAP your line of credit is required to be
       classified as a currently liability.  If you believe you
       are permitted to include these measures in future
       filings, please show us how you plan to revise your
       disclosures to comply with all of the disclosure
       requirements in Item 10(e) with respect to your
       presentation of such non-GAAP measures.
       Updated Company Response:  In future filings, we
       will eliminate the above referenced non-GAAP
       disclosures.
     5.   Comment:  Similar to the preceding comment, and in
       view of the rules related to non-GAAP measures, please
       tell us in detail why you believe it is appropriate to
       present your ratio of long-term debt to stockholders'
       equity as if your redeemable preferred stock represents
       permanent stockholders' equity, when under GAAP, such
       preferred stock is required to be classified outside of
       permanent stockholders' equity.  If you intend to
       present this measure in future filings, and you believe
       you are permitted to do so under Item 10(e), please show
       us how you plan to revise your disclosures in future
       filings to comply with Item 10(e).
       Updated Company Response:  In future filings, we
       will eliminate the above referenced non-GAAP
       disclosures.

As we discussed, I believe that our responses will
satisfy you and conclude your review.  We will look
forward to written confirmation from you that your
review is complete.   Should you have any questions,
please do not hesitate to call.  I may be reached at
(405)579-7144.

Sincerely,

Jodi Taylor
Chief Financial Officer
Harold's Stores, Inc.
Commission File No. 1-10892
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