SecProbe.io

Mail Stop 3561          November 5, 2008
Kosta N. Kartsotis, Chief Executive Officer
Fossil, Inc. 2280 N. Greenville Avenue Richardson, Texas 75082
 Re:  Fossil, Inc.
Form 10-K for Fiscal Year Ended January 5, 2008
  Filed March 5, 2008
Forms 10-Q for Fiscal Quarters Ended April 5 and July 5, 2008
  Filed May 15 and August 14, 2008
  Definitive Proxy Statement on Schedule 14A
Filed April 10, 2008
  File No. 000-19848

Dear Mr. Kartsotis:

We have reviewed your response letter  dated October 17, 2008 and have the
following comments.  Please provide a written response to our comments.  Please be as
detailed as necessary in your explanation.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

Form 10-K for the Fiscal Year Ended December 31, 2007

Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations, page 39

Summary, page 39

1. We note your response to comment 8 in  our letter dated September 25, 2008.
We request that you reconsider our comment and provide additional disclosure.
For example, where you state that “[p]urchases of discretionary fashion accessories, such as our watches, handbags, sunglasses and other products, tend to

Kosta N. Kartsotis
Fossil, Inc  November 5, 2008
Page 2

decline during recessionary periods…”  Please discuss if you are in fact
experiencing a recessionary trend in any of our markets and what you are doing to
address that trend.
 Liquidity and Capital Resources, page 51

2. We note your responses to comments 9 a nd 10 in our letter dated September 25,
2008.  Please provide a sample of how you inte nd to comply with this comment in
your future filings.
 Definitive Proxy Statement on Schedule 14A

 Executive Compensation, page 16

 Annual Cash Incentive Opportunities, page 20

3. We note your response to comment 13 in  our letter dated September 25, 2008,
which requested disclosure of your operating income targets.  We note your statement on page 20 of your proxy statement that you have a threshold for payout, a midpoint and maximum payment targ et.  Please disclose the minimum,
midpoint and maximum payment targets for 2007.

4. We note your response to comment 14 in our letter dated September 25, 2008 regarding benchmarking data provided by Ernst & Young.  Please clarify what, if
any, additional benchmark data that the Human Res ources Department provided
to the Executive Compensation Committee in addition to the Ernst & Young report.  Also, please discuss the Execu tive Compensation Committee’s analysis of
Ernst & Young’s recommendations.

Please respond to this comment within 10 business days or tell us when you will
provide us with a response.  Please furnish a letter that keys your response to our
comment and provides any requested information.  Detailed letters gr eatly facilitate our
review.  Please understand that we may have  additional comments after reviewing your
responses to our comment.

Kosta N. Kartsotis
Fossil, Inc  November 5, 2008
Page 2

Please contact Robert Errett, Attorney-A dvisor, at 202-551-3225, or Ellie Bavaria
Special Counsel at 202-551-3238, or me at 202-551-3725 with any questions.
Sincerely,

H. Christopher Owings  Assistant Director
  cc: Garret A. DeVries   Haynes and Boone, LLP   Facsimile (214) 200-0428