SecProbe.io

January 27, 2025
Dennis Secor
Interim Chief Financial Officer
Guess?, Inc.
Strada Regina 44
Bioggio, Switzerland CH-6934
Re:Guess?, Inc.
Form 10-K for the Fiscal Year Ended February 3, 2024
Filed April 1, 2024
Form 10-Q for the Fiscal Quarter Ended November 2, 2024
Filed December 6, 2024
File No. 001-11893
Dear Dennis Secor:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.

January 27, 2025
Page 2
Form 10-Q for the Quarter Ended November 2, 2024
Notes to the Financial Statements
(2) Acquisition of rag and bone, page 10
1.We note your disclosure on page 12 of actual and pro forma net revenue information
related to the November 2, 2024 acquisition of rag & bone. Please revise future filings
to also include disclosure of the earnings of the acquired entity since the acquisition
date, as included in the consolidated income statement, as well as earnings of the
combined entity for the period as if the acquisition of rag & bones had been as of the
beginning of the annual reporting period (supplemental pro forma earnings
information). See guidance in ASC 805-10-50-2(h).
Form 10-K for the Year Ended February 3, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Information by Business Segment, page 53
2.Although we note that earnings (loss) from operations at the segment level represents
a required ASC 280 measure, please note that the measure on a total combined
basis outside of the notes to the financial statements represents a non-GAAP measure.
See Question 104.04 of the Compliance and Disclosure Interpretations on Non-GAAP
Financial Measures ("Non-GAAP C&DI's"). Accordingly, if you continue to present
such measure outside of your consolidated financial statements, please label it as a
non-GAAP financial measure and ensure that your presentation and disclosures fully
comply with non-GAAP rules, including Item 10(e) of Regulation S-K and the Non-
GAAP C&DI's. The comment also applies to such non-GAAP measures disclosed in
earnings releases furnished in Forms 8-K.
Notes to the Financial Statements
(1) Description of the Business and Summary of Significant Accounting Policies and
Practices
Revenue Recognition, page F-10
3.We note that your statements of income disclose revenue by product sales and royalty
income. We also note that your segment disclosure in Note 17 includes disclosure of
revenue by geographic area of which some include wholesale and retail
designation. Please tell us how you considered further disaggregation of your revenue
as required by paragraphs ASC 606-10-50-5 and ASC 606-10-55-89 through 55-91,
such as by product type or e-commerce and retail sales. In this regard, we note that on
your earnings calls you discuss revenue by certain product groupings, such as
accessories versus apparel, and women’s apparel, footwear, Marciano business,
etc. Please advise or revise future filings accordingly. See also guidance in ASC 280-
10-50-40.
(17) Segment Information, page F-51
We note your reconciliation of total segment earnings from operations excluding 4.

January 27, 2025
Page 3
corporate overhead, asset impairment charges, net gains (losses) on lease
modifications, and gain on sale of assets to total earnings from operations. Please note
that ASC 280-10-50-30(b) requires a reconciliation of the total of the reportable
segments’ measures of profit or loss to the public entity’s consolidated income before
income taxes. In future filings, please revise your reconciliation to comply with this
guidance.
5.We note that your segment measure of profit or loss is earnings (loss) from
operations. As required by ASC 280-10-50-22, please revise future filings to include
disclosure of depreciation and amortization by segment as that amount appears to be
included in your segment profitability measure.
            In closing, we remind you that the company and its management are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of action by the staff.
            Please contact Stephany Yang at 202-551-3167 or Claire Erlanger at 202-551-3301
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing