SecProbe.io

CORRESP
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 July 28, 2025

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Trade and Services

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn: Suying Li and Rufus Decker

 Re:
 Citi Trends, Inc.

 Form 10-K for Fiscal Year Ended February 1, 2025

 Item 2.02 Form 8-K dated June 3, 2025

 Response dated July 2, 2025

 File No. 001-41886

 Dear Ms. Li and Mr. Decker:

 We hereby respond to the comments
of the staff (the "Staff") of the Securities and Exchange Commission (the "Commission"), as set forth in the Staff's
letter of comments dated July 14, 2025 (the "Comment Letter"), to the above referenced filings of Citi Trends, Inc. (the "Company").
The Company has filed, via EDGAR, this letter (tagged Correspondence).

 The Company has the following
response to the Staff's comment in the Comment Letter. For your convenience, we have reproduced in italics below the comment from
the Comment Letter with the response following.

 Item 2.02 Form 8-K dated June 3, 2025

 Exhibit 99.1

 1. We note your response to the second bullet
point of prior comment 2. In your proposed revised disclosure, you present net income flowthrough as adjusted, which appears to be a non-GAAP
measure. Please provide all of the disclosures required by Item 10(e) of Regulation S-K. Also, the most directly comparable GAAP measure
to adjusted EBITDA flowthrough is net income flowthrough and not total sales. In addition, please remove your disclosures implying that
a non-GAAP measure reflects operating results that are more indicative of your ongoing operating performance while improving comparability
to prior and future periods than a GAAP measure. Finally, disclose the additional purpose, if any, for which your management uses the
adjusted EBITDA flowthrough measure. Refer to Item 10(e)(1)(i)(B) and (D) of Regulation S-K and Question 103.02 of the Non-GAAP Financial
Measures Compliance and Disclosure Interpretations.

 The Company respectfully acknowledges
the Staff's comment and agrees that the most directly comparable GAAP measure to adjusted EBITDA flowthrough is Net Income flowthrough.
By way of illustration, the Company provides the below example as if this had been included in its earnings release furnished as Exhibit
99.1 to its Form 8-K filed June 3, 2025:

 Financial Highlights – First Quarter
2025

 ·
 Net Income flowthrough of 28%, from total sales increase of $15.4 million versus last year and Net Income increase of $4.3 million

 ·
 Adjusted Net Income flowthrough* of 26%, from total sales increase of $15.4 million versus last year and Adjusted Net Income* increase of $4.08 million

 ·
 Adjusted EBITDA Flowthrough* of 40%, above Company expectations, from total sales increase of $15.4 million versus last year and adjusted EBITDA* increase of $6.2 million

 The Company included reconciliations
for both Adjusted Net Income and Adjusted EBITDA to their most directly comparable GAAP measure, Net Income, for both periods presented
as part of Exhibit 99.1 to its Form 8-K file June 3, 2025. As such, the period over period increases presented in the flowthrough calculations
above are reconciled to the most directly comparable GAAP measure.

 Additionally, the
Company respectfully acknowledges the Staff's comment regarding the disclosure of usefulness of non-GAAP measures, including
the adjusted EBITDA flowthrough measure, and advises the Staff that, in the Company's future earnings releases furnished under
Item 2.02 of Form 8-K, the Company will remove the statement that non-GAAP financial measures are "more indicative" of
the Company's ongoing operating performance. Below is the suggested language to be included in future earnings releases or
other current or periodic reports where non-GAAP measures, including the adjusted EBITDA flowthrough measure, are presented:

 "The Company sometimes use financial
measures that are derived from the consolidated financial statements but that are not presented in accordance with GAAP to understand
and evaluate the Company's current operating performance and to allow for period-to-period comparisons. The Company believes these
non-GAAP financial measures may also provide useful information to investors and others. These non-GAAP measures may not be comparable
to similarly titled non-GAAP measures of other companies and should be considered in addition to and not as a substitute for or superior
to, any measure of performance, cash flow or liquidity prepared in accordance with GAAP. The Company is providing a reconciliation of
reported non-GAAP financial measures to their comparable financial measures on a GAAP basis."

 ***

 Sincerely,

 /s/ Heather Plutino

 Heather Plutino

 Chief Financial Officer

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