SecProbe.io

Mail Stop 3561

June 2 6, 2018

Scott M. Settersten
Chief Financial Officer, Treasurer and Assistant Secretary
Ulta Beauty, Inc.
1000 Remington Blvd., Suite  120
Bolingbrook, Illinois 60440

Re: Ulta Beauty, Inc.
 Form 10-K for the Fiscal Year Ended February 3, 2018
Filed April 3, 2018
Form 10 -Q for the Quarterly Period Ended May 5, 2018
Filed June 1, 2018
Form 8 -K filed on March 15 , 2018
File No. 001-33764

Dear Mr. Settersten :

We have reviewed your filing an d 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you w ill respond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have additional comments.

Form 10 -K for the Fiscal Year En ded February 3, 2018

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Results of Operations

Gross Profit, page 32

1. To the extent material, p lease separately discuss  and quantify the effect e -commerce sales
have on your gross profit .

Scott M. Settersten
Ulta Beauty, Inc.
June 26 , 2018
Page 2

 Form 10 -Q for the Quarterly Period ended May 5, 2018

Item 1 Financial Statements

Notes to Consolidated Financial Statements

1. Business and basis of presentation, page 7

2. We note from your disclosure on page 16 that you aggregate your retail stores, salon
services, and e -commerce operating segments into one reportable segment.  It appears
from your disclosure on page 12 and from your fourth quarter 2017 earnings call
transcript that e -commerce net sales were 10% and “near ly 30%” of total net sales for the
first quarter of 2018 and fourth quarter of 2017, respectively.  Explain to us how you
evaluated the aggregation criteria in ASC 280 -10-50-11 in determining you have only
one reportable segment.  In doing so, explain in s ufficient detail how you determined
your operating segments have similar economic characteristics.  We note from your most
recent Forms 10 -K and 10 -Q that retail store and e -commerce comparable sales increases
were materially different for all periods pres ented.  We further note management’s
statements during your fourth quarter 2017 earnings call that e -commerce sales have
margins below that of your brick and mortar business.

Form 8 -K filed March 15, 2018

3. We note that you adjust diluted EPS for the one -time hourly associates bonus on an after -
tax basis.  In future filings, p lease present such adjustments on a pre -tax basis  with
separate disclosure of the  related income tax impact to comply with Non -GAAP
Financial Measures C&DI 102.11.

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.

You may contact  Robert Babula, Staff Accountant at  (202) 551 -3339, or Andr ew Blume,
Staff Accountant  at (202) 551 -3254,  if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202) 551 -3737 with any other questions.

Sincerely,

 /s/ Jennifer Thompson

Jennifer Thompson
Accounting Branch Chief
Office of Con sumer Products