SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 January 21, 2026

John Szczepanski
Chief Financial Officer and Principal Accounting Officer
The Children's Place, Inc.
500 Plaza Drive
Secaucus, NJ 07094

 Re: The Children's Place, Inc.
 Form 10-K for the Fifty-Two Weeks Ended February 1, 2025
 Form 8-K filed April 11, 2025
 Form 10-Q for the Quarterly Period Ended November 1, 2025
 File No. 000-23071
Dear John Szczepanski:

 We have reviewed your filing and have the following comment(s).

 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.

Form 10-K for the Fifty-Two Weeks Ended February, 1 2025
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations, page 37

1. You discuss adjusted selling, general and administrative expenses and
adjusted operating
 income leveraged basis points and percentages of net sales without
presenting or
 discussing the most directly comparable GAAP measure with equal or
greater
 prominence. Please revise future disclosures to comply with Item
10(e)(1)(i)(A) of
 Regulation S-K or explain why a revision is not necessary. Refer to
Question 102.10(a)
 of the Staff s Compliance and Disclosure Interpretations on Non-GAAP
Financial
 Measures.
Non-GAAP Reconciliation, page 37

2. We note numerous adjustments to your non-GAAP measures in Fiscal 2024.
Please tell
 us your consideration of providing reconciliations in tabular form for
clarity. Refer to
 Item 10(e)(1)(i)(B) of Regulation S-K.
 January 21, 2026
Page 2

Form 8-K filed April 11, 2025
Exhibit 99.1, page 1

3. The second line item on page 1 reports the third consecutive quarter of
adjusted
 profit and discussions on pages 3 and 4 discuss adjusted selling,
general and
 administrative expenses and adjusted operating income leveraged basis
points and
 percentages of net sales without presenting or discussing the most
directly comparable
 GAAP measure with equal or greater prominence. Please revise future
disclosures to
 comply with Item 10(e)(1)(i)(A) of Regulation S-K or explain why a
revision is not
 necessary. Refer to Question 102.10(a) of the Staff s Compliance and
Disclosure
 Interpretations on Non-GAAP Financial Measures.
4. Reference is made to page 7. Please tell us the Adjusted net income
(loss) effective tax
 rate for each period presented and explain why it's reasonable. In this
regard, tell us your
 consideration of including current and deferred income tax expense
commensurate with
 this non-GAAP measure of profitability. Refer to Question 102.11 of the
Staff s
 Compliance and Disclosure Interpretations on Non-GAAP Financial
Measures.
Form 10-Q for the Quarterly Period Ended November 1, 2025
Financial Statements
Consolidated Statements of Cash Flows, page 6

5. Reference is made to your "Proceeds from rights offering" and "Repayment
of related
 party term loan" line items. We note your disclosure on page 17 that
$60.2 million worth
 of shares was paid with the delivery of indebtedness of borrowed money
owed by you to
 Mithaq and you received $29.8 million in gross proceeds from the Rights
Offering.
 Please tell us your consideration of reflecting only $29.8 million of
proceeds from the
 Rights Offering and a $60.2 million non-cash financing activity in your
Consolidated
 Statements of Cash flows. Refer to ASC 230-10-50-3 through 50-6.
 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 Blaise Rhodes at 202-551-3774 or Adam Phippen at
202-551-3336 if you
have any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
</TEXT>
</DOCUMENT>