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Retail Ventures, Inc.     Correspondence

December 14, 2005

Ms. Sarah Goldberg

Staff Accountant

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Mail Stop 3561

Washington, D.C. 20549

    Re:

    Retail Ventures, Inc.

    Form 8-K Filed December 8, 2005

    File No. 1-10767

Dear Ms. Goldberg:

We have received your comments to the Form 8-K filed December 8, 2005 set forth in your letter
dated as of December 9, 2005.

To reduce the likelihood of confusion, we have included your comment in bold font with our response
below it. We respectfully respond to the comment as follows:

Form 8-K

Item 4.02(a)

    1.

    Please explain to us in greater detail the nature of the deferred tax liability and
how you determined the previously reported amount was incorrect. Further, as the deferred
tax liability relates to the initial public offering of DSW, Inc., which occurred on June
29, 2005, please explain why the restatement does not affect the statement of operations
for the fiscal quarter ended July 30, 2005.

As you noted in your letter dated December 9, 2005, the deferred tax liability that Retail
Ventures, Inc. (the “Company”) has determined to be incorrect was related to taxes recorded in
connection with the initial public offering (“IPO”) of DSW Inc. (“DSW”). Prior to the IPO, DSW was
a wholly owned subsidiary of the Company and under paragraph 33 of Financial Accounting Standard
No. 109 Accounting for Income Taxes (“FAS 109”), no deferred taxes were recorded as the Company
expected to be able to realize its investment in DSW without incurring any taxes. However, when
its ownership was reduced by the IPO, the Company could no longer make the necessary assertion
required by paragraph 33 (that “the enterprise expects that it will ultimately use that means”
means referring to tax-free means). Not meeting the exception to the recording of deferred taxes
provided by paragraph 33 of FAS 109, the Company recorded the deferred taxes for the difference in
basis between financial reporting and tax that existed immediately after the IPO.

During the financial closing and reporting process for the third quarter of Fiscal 2005, the
Company identified an error in its calculation and reporting of deferred income taxes and retained
earnings that required an adjustment to the Condensed Consolidated Balance Sheet in the Company’s
Form 10-Q as filed with the Securities and Exchange Commission on September 13, 2005. The Company
determined that it should have reported the full amount of the deferred income tax liability
associated with the outside basis difference of $62.5 million instead of the previously reported
deferred income tax liability of $39.7 million. The difference between the corrected amount and the
amount originally reported relates to the amount of deferred tax assets recorded by DSW in the
amount of $22.8 million, which was mistakenly subtracted from the full amount of deferred tax
liability associated with the outside basis difference in DSW. The result of this correction is to
increase the deferred tax liability on the books of the parent, Retail Ventures, Inc., to the full
amount of deferred tax liability associated with the basis difference without affecting the net
deferred tax asset of $22.8 million, which was correctly recorded on the financial statements of
DSW.

The Company reviewed Staff Accounting Bulletin Topic 5 H, which under certain circumstances, allows
companies to elect to record the gain from the sale of stock by a subsidiary to the statement of
operations. However, the Company elected to record the increase in the value of their investment
in the common stock of DSW, as a result of the IPO, into equity, thereby selecting that method as
its accounting policy. Therefore, the correction of the error described above would also be made
directly to equity and would not affect the statement of operations.

Finally, as requested, the Company acknowledges the items set forth after bullets at the conclusion
of your December 9, 2005 letter.

If you have any questions regarding any of the foregoing, please contact the undersigned at (614)
478-2300.

Thank you for your assistance with this matter.

Sincerely,

/s/ James A. McGrady

James A. McGrady

Executive Vice President, Chief Financial Officer,

Treasurer and Secretary

    cc:

    Heywood Wilansky, Chief Executive Officer

    Julia A. Davis, Executive
Vice  President and

General Counsel

    Harvey Sonnenberg, Chairman of the
Audit
  Committee

    Michael Cline, Partner

Vorys, Sater, Seymour and Pease LLP