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      March 4,
2010

      VIA EDGAR
Correspondence

      Adam
Phippen

      Division
of Corporation Finance

      U.S.
Securities and Exchange Commission

      100 F
St., NE

      Washington,
DC 20549

      Re:           Signet
Jewelers Limited

      Form 20-F
for the Year Ended January 31, 2009

      Filed April 1, 2009

      File No.
001-32349

      _______________________________________

      Dear Mr.
Phippen:

      This
letter responds to a comment of the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) contained in telephone conversations with
Andrea Bernstein and P.J. Himelfarb at Weil, Gotshal & Manges LLP following
a letter from Signet Jewelers Limited (the “Company”), dated January 22, 2010.
The Company’s letter was in response to the Commission’s letter dated December
23, 2009 (the “Comment Letter”), related to the Form 20-F (the “Form 20-F”) for
the fiscal year ended January 31, 2009, which was filed on April 1, 2009. Set
forth below in bold is the Staff’s comment and immediately following the Staff’s
comment is the Company’s response including example language that we propose to
incorporate into prospective filings with the Commission in response to the
Staff’s comment.

      Please
tell us your policy for accounting for the sale of items that have been held as
consignment inventory and the basis for such policy. Please disclose such policy
in future filings.

      Response:

      The
Company held $202.1 million of consignment inventory at January 31, 2009 and
made $310.4 million of sales of items from consignment inventory during the year
ended January 31, 2009.

      When
consignment inventory is sold, the sale is accounted for on a gross sales basis.
Management considers this accounting treatment  to be appropriate
based upon an evaluation of the factors for determining sales accounting
treatment as prescribed in EITF 99-19 (ASC 605-45). The factors supporting gross
revenue accounting are as follows:

              Signet
Jewelers Limited, Clarendon House, 2 Church Street, Hamilton HM 11,
Bermuda

            Registered in Bermuda number
42069

                ·

                The
      Company acts as a principal in the transaction and considers that it is
      the primary obligor as it selects the products and determines the price
      for these items.

                ·

                The
      Company provides independent advice and guidance to customers and after
      sales service.

                ·

                The
      products sold from consignment inventory are indistinguishable to the
      customer from other products that are sold from purchased inventory as
      they are sold on the same terms and are not separately identified as
      consignment items in the stores.

                ·

                The
      Company selects the products and suppliers at its own
      discretion.

                ·

                The
      Company is responsible for the physical security of the products held on
      its premises and is therefore liable for any inventory
    loss.

                ·

                The
      Company also takes the credit risk of a sale to the
    customer.

      This
treatment on a gross sales basis is further supported by there being no
indicators for net revenue accounting as:

                ·

                The
      Company (not the supplier) is the primary obligor in the
      arrangement;

                ·

                The
      amount the Company earns is variable and not a fixed fee or percentage per
      transaction; and

                ·

                The
      Company (not the supplier) takes the credit
  risk.

      Future
filings will contain the following disclosure within ‘Revenue recognition’ under
principal accounting policies (on page 122 of the Form 20-F):

      Sales of
Consignment Inventory

      Sales of
consignment inventory are accounted for on a gross sales basis . This reflects
that the Company is the primary obligor providing independent advice guidance
and after sales service to customers. The products sold from consignment
inventory are indistinguishable to the customer from other products that are
sold from purchased inventory. They are sold on the same terms and are not
separately identified as consignment items in the stores. The Company selects
the products and suppliers at its own discretion and is responsible for the
physical security of the products making it liable for any inventory loss. It
also takes the credit risk of a sale to the customer.

      In
responding to these comments, the Company acknowledges 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 comments as a defense in any proceeding
      initiated by the Commission or any person under the federal securities
      laws of the United States.

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      If you
have any further questions or comments, please do not hesitate to contact me on
011-44-870-909-0301 or Andrea Bernstein at Weil, Gotshal & Manges LLP at
(212) 310-8528. You may also address queries to Mike Maloney of KPMG in London
at 011-44-207-311-1000.

      Sincerely,

        /s/
Walker Boyd

      Walker
Boyd

      Group
Finance Director

      Signet
Jewelers Limited

      cc H.
Christopher Owings (Division of Corporation Finance)

          Andrea
Bernstein (Weil, Gotshal & Manges LLP)

          Mike
Maloney (KPMG)

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