SecProbe.io

January 12, 2015

Via E -mail
Michele L. Santana
Chief Financial Officer
Signet Jewelers Limited
Clarendon House
2 Church Street
Hamilton JM11
Bermuda

Re: Signet Jewelers Limited
 Form 10-K for the Fiscal Year Ended February 1, 2014
 Filed March 27, 2014
Form 10-Q for the Quarterly Period Ended November 1, 2014
Filed December 8, 2014
File No. 1 -32349

Dear Mrs. Santana :

We have reviewed your filing s and have the following comments.  We have limited our
review to only your financial statements and related disclosures and do not intend to expand our
review to ot her portions of your documents.  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 s, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do no t believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing s and the information you provide in
response to these  comments,  we may have  additional comments.

Form 10 -K for the Fiscal Year Ended February 1, 2014

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 54

Sales, page 55

1. We note your disclosure that eComm erce sales are included in the calculation of sales for
the period and the comparative figures from the anniversary of the launch of the relevant
website.  Please tell us whether this disclosure means that eCommerce sales are included

Michele L. Santana
Signet Jewelers Limited
January 12, 2015
Page 2

 in your same stores s ales performance measures.  In any event, please clarify your
disclosure to clearly state whether eCommerce sales are included in same store sales.  In
addition, please tell us your consideration of disclosing the specific impact that
eCommerce sales had o n same stores sales performance.

Liquidity and Capital Resources, page 74

2. Please tell us your consideration of disclosing the amount of cash and cash equivalents
and short term investments held by foreign subsidiaries; a statement that you will need to
accrue and pay taxes if repatriated; and a statement that you do not intend to repatriate the
funds.

Item 8. Financial Statements and Supplementary Data, page 86

Consolidated Statements of Shareholders’ Equity, page 91

3. Please tell us the nature of the activity flowing through the “net settlement of equity
based awards” line items and why your accounting treatment is appropriate.  Please make
reference to the authoritative literature that supports your accounting.

4. Please tell us how excess tax benefits from exercise of share awards are presented in the
statement.

Notes to the Consolidated Financial Statements, page 92

1. Principal accounting policies, page 92

Sale vouchers, page 93

5. Referencing applicable authoritati ve literature, please explain to us the nature of your
sales vouchers and your accounting for sales vouchers.  In doing so, please explain your
accounting for vouchers issued which are not expected to be redeemed.

5. Income taxes, page 101

6. Please tell us  your consideration of disclosing the amount of the unrecognized deferred
tax liability for temporary differences related to investments in foreign subsidiaries and
foreign corporate joint ventures that are essentially permanent in duration if
determinatio n of that liability is practicable or a statement that determination is not
practicable.  Refer to ASC 740 -30-50-2c.

Michele L. Santana
Signet Jewelers Limited
January 12, 2015
Page 3

 15. Accrued expenses and other current liabilities, page 110

7. Please tell us your consideration of disclosing gross sales returns reserve activity here or
in Management’s Discussion and Analysis of Financial Condition and Results of
Operations.

Form 10 -Q for the Quarterly Period Ended November 1, 2014

Part I. Financial Information, page 1

Item 2. Management’s Discussion and Analys is of Financial Condition and Results of
Operations, page 40

Overview, page 40

Earnings before interest, income taxes, depreciation and amortization (“EBITDA”), page 43

8. The non -GAAP measure presented does not represent EBITDA.  Rather, the measure is
EBTIDA adjusted for other non -cash accounting adjustments.  If a similar measure is
presented in future filings, please refer to it as Adjusted EBITDA or similarly to clearly
communicate that the measure is not EBITDA.

We urge all persons who are responsibl e for the accuracy and adequacy of the disclosure
in the filing s to be certain that the filing s include the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possessi on 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 provide  a written statement from the company
acknowledging that:

 the compan y is responsible for the adequacy and accuracy of the disclosure in the filing s;

 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 s; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Michele L. Santana
Signet Jewelers Limited
January 12, 2015
Page 4

 You may contact Adam Phippen, Staff Accountant , at (202) 551 -3336  or me at (202)
551-3344  if you have questions regarding our comments or any other questions.

Sincerely,

 /s/ William H. Thompson

William H. Thompson
Accounting Branch Chief

cc:  Mark Jenkins
 Chief Governance Officer & Corporate Secretary