SecProbe.io

July 3 , 2014

Via E -mail
Mr. Michael Scarpa
Chief Financial  Officer
The Children’s Place, Inc.
500 Plaza Drive
Secaucus, NJ 07094

 Re:  The Children’s Place,  Inc.
  Form 10 -K for the Fiscal Year Ended February 1, 2014
  Filed March 20 , 2014
  File No. 000 -23071

Dear Mr. Scarpa :

We have reviewed your filing  and have the following comments . 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 providing the requested
information, or by advising us when you will provide the requested response. If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

 After reviewing any  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 8.  Financial Statements and Supplementary Data, page 40
Note 1.  Basis of Presentation and Summary of Significant Accounting Policies, page 53
Short -term Investments, page 53

1.  We note you purchased $15  million in short -term investments during the year ended
February 2, 2013 and an addition $47.5 million during the year ended February 1, 2 014.
As of February 1, 2014, you held $62.5 million of short -term investments, all in Hong
Kong .  We also note you h ave classified these investments as held -to-maturity.  Please
provide the following:

 additional information about the types of securities and the maturity dates;

Michael Scarpa
The Children’s Place, Inc.
July 3, 2014
Page 2

  clarify whether  you sold or redeemed the investments purchased in fiscal year 2012
and if not, e xplain how these investments qualify  to be classified as short -term;  and

 confirm you will present any purchase  and sale/redemption of short -term investments
on a gross basis  in your statement of cash flows in accordance with ASC 230 -10-45-
26 in future filings.

2.  Please quantify and explain how you record the foreign translation adjustment related to
these short -term investments. Please clarify whether these funds are available for general
corporate use as your investments in foreign subsidiaries are considered per manently
reinvested. Please expand your accounting policy to disclose your accounting of the
foreign translation adjustment on these short -term investments and provide draft
disclosure to be included in future filings.

Note 11 .  Income Taxes, page 68

3.  We note that you r reconciliation between the actual and expected income tax includes a
significant line item for foreign tax rate differentials.  In order to provide investors with
greater insight into this item that affects  your income taxes, please ex pand your
disclosur e in future filings .  For example, discuss how the tax rate differential is
determined and identify the significant components of these items .  Also, discuss what
countries contribute to this tax rate differential and whether there are a ny known
uncertainties or trends in the lower tax jurisdictions that could affect  your income taxes in
future periods.   Refer to Item  303(a) of Regulation S -K.  Provide us with a sample of
your proposed revised disclosure.

We urge all persons who are re sponsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require. Since the company and its management are
in po ssession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclos ures they have made.

Michael Scarpa
The Children’s Place, Inc.
July 3, 2014
Page 3

 In responding to our comments, please provide a written statement from the company
acknowledging that:

 the co mpany 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.

You may contact Myra Moosariparambil  at (202) 551 -3796  or Nasreen Mohammed at
(202) 55 1-3773  if you have questions regarding comments on the financial statements and
related matters.   Please contact  me at (202) 551 -3871 with any other questions.

Sincerely,

/s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel, and
Mining