SecProbe.io

Mail Stop 3561

         August 25, 2008  Mark Jenkins Group Company Secretary Signet Group plc 15 Golden Square London W1F 9JG England
 Re:  Signet Group plc
  Form 20-F for Fiscal Year Ended February 2, 2008
  Filed May 9, 2008   File No. 001-32349
Dear Mr. Jenkins:
  We have reviewed your filing and have the following comments.  You should comply with the comments in all future filings, as appl icable.  Please confirm in writing that you will do
so, and also explain to us in sufficient detail for an understa nding of the disclosure how you
intend to comply by providing us with your prop osed revisions.  If you disagree, we will
consider your explanation as to why our comments are inapplicable or a revision is unnecessary.
Please be as detailed as necessa ry in your explanation.  After re viewing this information, we may
raise additional comments.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filings.  We look forward to working with  you in these respects.  We welcome any
questions you may have about our comments or on any other aspect of our review.  Feel free to
call us at the telephone numbers lis ted at the end of  this letter.
 Form 20-F for Fiscal Year Ended February 2, 2008

Exhibit 15.3

Directors Remuneration Report, page 67
Directors’ Interests in Shares, page 76

1. Please provide the percentage ownership of each  of the directors li sted in the table on
page 79 in accordance with Item 6E of Form 20-F.

Mark Jenkins
Signet Group plc August 25, 2008
Page 2   Note 1. Principal accounting policies, page 86

(a) Basis of preparation, page 86
 2. Please explain to us in greater detail the f acts and circumstances leading to your election
to change your reporting and functional curr ency from UK pounds to US dollars.  In
particular, address why the timing of the ch ange in February 2007 was appropriate as
opposed to some earlier date.  We  may have further comment.
 Note 21. Employee benefit costs – pension schemes, page 104

3. Since you incorporate by reference Form 20- F in registration statements on Form S-8,
you may have to name and file the written consent of the independent qualified actuary
you reference to the extent they  qualify as an expert.  In this regard, please explain the
nature and extent of the actuary’s involve ment in your decision-making process as it
relates to the matter in which the actuary partook.  Alternatively, you may remove the reference to the independent qualified actuary.  If you do not believe a consent is required, please explain in detail.  Refer to  Section 436(b) of Re gulation C and Section
7(a) of the Securities Act of 1933.
 Note 27. Share options, page 113

 4. Reference is made to your disclosure on page  90 that a liability is recognized for cash
settled share schemes.  In this regard, for each share-based payment arrangement, please disclose whether settlement will be in cash or  shares.  Additionally, disclose the vesting
requirements for each arrangement.  Refer to paragraph 45(a) of IFRS 2.  Furthermore,
for liabilities arising from share-based paymen t transactions, please disclose the total
carrying amount at the end of the period and the total intrin sic value at the end of the
period of liabilities for which the counterparty’s  right to cash or othe r assets had vested
by the end of the period.  Refer to  paragraph 51(b) of IFRS 2.
 Shareholder Information, page 129

Information on Share Buyback Programme, page 131
 5. Please revise the table on page 131 to conform to the requirements of  Item 16E of Form
20-F.

*****

Please respond to these comments within 10 business days or tell us when you will
provide us with a response.  Please furnish a letter that keys your respon ses to our comments and
provides any requested information.  Detailed letters greatly facilitate  our review.  Please

Mark Jenkins
Signet Group plc August 25, 2008 Page 3
 understand that we may have additional comments after reviewing your responses to our comments.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filings to be certain that the filings include all information required under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision.  Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they ar e responsible for the adequacy and accuracy of
the disclosures they have made.
 In connection with responding to our comment s, please provide, in writing, a statement
from the company acknowledging that:

• the company is responsible for the adequacy  and accuracy of the disclosure 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the sta ff of the Division of Corporati on Finance in our review of your
filings or in response to our comments on your filings.

You may contact Sarah Goldberg, Assistant Chief Accountant, at (202) 551-3340 or Jim
Allegretto, Senior Assistant Chief Accountant, at (202) 551-3720 with an y questions regarding
the comments on financial statements and related matters.  You may contact  Blair Petrillo, Staff
Attorney, at (202) 551-3550 or me at (202) 551-3720 with any other questions.

Sincerely,

H. Christopher Owings Assistant Director