SecProbe.io

September 12, 2011

Via Email
R. David Alexander, Jr. Chief Executive Officer Citi Trends, Inc. 104 Coleman Blvd. Savannah, GA  31408
Re: Citi Trends, Inc.
 Form 10-K for Fiscal Year Ended January 29, 2011
Filed April 13, 2011 File No. 000-51315

Dear Mr. Alexander:
 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 amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for Fiscal Year Ended January 29, 2011

 Management’s Discussion and Analysis

 Overview, page 20

1. We note you prominently display EBITDA in your management overview and consider
such measure to “[y]our most important operatin g statistic.”  Considering such measure is
not mentioned anywhere else in your Excha nge Act filings, in your press releases or
during your investor conference calls, please (i) confirm in future filings you will revise
your disclosure to explicitly clarify the r easons why you believe that presentation of
EBITDA (and Adjusted EBITDA in your July  30, 2011 Form 10-Q) provides useful
information to investors regarding your fina ncial condition and resu lts of operations and
(ii) provide us with draft di sclosure of your planned revisi ons.  Refer to Item 10(e)(i)(C)
of Regulation S-K.  We may have additiona l comments upon review of such disclosure.

R. David Alexander Jr.
Citi Trends, Inc. September 12, 2011 Page 2

 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

You may contact Blaise R hodes at 202 551-3774 or Brian Bhandari at 202 551-3390 if
you have questions regarding comments on the fi nancial statements and related matters.

Sincerely,
   /s/ Brian K. Bhandari for
Tia Jenkins
Senior Assistant Chief Accountant