SecProbe.io

October 11 , 2013

Via E -Mail
Mr. Joseph B. Parsons
Chief Financial  Officer
Michael Kors Holdings Limited
Unit 1902
19/F, Tower 6
The Gateway
Harbour City
Tsim Sha Tsui , Kowloon, Hong Kong

Re: Michael Kors Holdings Limited
 Form 10-K for the Fiscal Year Ended March 30, 2013
Filed May 29 , 2013
Response dated October 3, 2013
File No. 001-35368

Dear M r. Parsons :

We have reviewed your response and 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 this letter within ten busine ss days by amending your filing , by
providing the requested information, or by advising us when you will provide the requested
response.   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 an y amendment to your filing and the information you provide in
response to these comments, we may have additional comments .

Form 10 -K for the Fiscal Year Ended March 31, 2013

Management ’s Discussion and Analysis of Financial Condition and Results of Operations , page
22
General Definitions for operating  results, page 2 7

1. We note your response to prior comment 3 from our letter dated September 25, 2013 and
see that you have provided proposed disclosure indicating that certain costs are not
included in costs of goods sold and that your costs of goods sold may not be comparable
to that of other entities.  However, your proposed disclosure does not state that your gross

Mr. Joseph B. Parsons
Michael Kors Holdings Limited
October 11 , 2013
Page 2

 profit may not be comparable to those of other entities.   Please revise your proposed
disclosure accordingly.  In addition, your revised dis close should also indicate that
depreciation and amortization are not included in cost of goods sold or gross profit.

Consolidated Sta tements of Operations and Comprehen sive In come, page 46

2. We note cost of sales in your statement of operations exclude charges for depreciation
and amortizati on.  Please tell us how your presentation of cost of goods sold complies
with the guidance in SAB Topic 11 .B or provide revised disclosure to be included in
future filings.

Schedule 14A  filed June 18, 2013

Certain Relationships and Related Person Tran sactions, page 26

3. We note your response to comment 2 of our letter dated September 25, 2013 and the draft
language disclosing each related party’s ownership interest in Michael Kors Far East
Holdings Limited.  Please also provide the disclosure required b y Item 404(a)(4) of
Regulation S -K regarding the dollar value of each related party’s interest in the Far East
Licensing Agreements, as previously requested.  Please provide us with draft disclosure
for inclusion in future filings.

We urge all persons who  are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management a re
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.

You may contact Brian McAllister , Staff Accountant at (202) 551 -3341  or Craig
Arakawa , Accounting Bra nch Chief  at (202) 551 -3650  if you have questions regarding
comments on financial statements and related matters.  Please contact Erin Wilson at (202) 551 -
6047 or Jay Williamson at (202) 551 -3393 with any other questions.

        Sincerely,

        /s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel, and
Mining