SecProbe.io

December 9, 2011
 Via Facsimile

Mr. John D. Idol, Chief Executive Officer Michael Kors (USA), Inc. 11 West 42
nd Street, 21st Floor
New York, NY 10036
Re: Michael Kors Holdings Limited
Registration Statement on Form F-1 Filed December 2, 2011
  File No. 333-178282

Dear Mr. Idol:

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 by amending your registration statement and providing the
requested information.  If you do not believe  our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.

Form F-1, filed December 2, 2011

 General

1. We remind you that the outstanding comme nts regarding your application for
confidential treatment must be cleared pr ior to your request for effectiveness.
 Summary Historical Consolidated Financial and Other Data, page 8

2. Please label “weighted average ordinary shar es outstanding” and the “net income per
ordinary share” with footnote (4) as it appears that these values give effect to the Share
Split and the conversion of all outstanding pr eference shares into ordinary shares
immediately prior to the completion of this offering.

John D. Idol Michael Kors Holdings Limited December 9, 2011 Page 2

 Consolidated Financial Statements

 Notes to Consolidated Financial Statements

 1. Business and Basis of Presentation, page F-7

3. It appears that your disclosure here wh ich states that the 3.8 to 1 share split
occurred on November 30, 2011 is inconsiste nt with the disclosure presented on
page 7 which states the share split occurred on December 1, 2011.  Please clarify
or revise.

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 incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

John D. Idol Michael Kors Holdings Limited December 9, 2011 Page 3

You may contact Jamie Kessel at (202) 551-3727 or Angela Halac at (202) 551-3398 if
you have questions regarding comments on the fina ncial statements and related matters.  Please
contact Erin Wilson at (202) 551-6047 or Ja mes Lopez at (202) 551-3536 with any other
questions.
Sincerely,
   /s/ James Lopez (for)
John Reynolds Assistant Director