SecProbe.io

Mail Stop 3561
September 21 , 2015

Via E -mail
John D. Idol
Chairman and Chief Executive Officer
Michael Kors Holdings Ltd.
33 Kingsway
London, United Kingdom
WC2B 6UF

Re: Michael Kors  Holdings Ltd.
 Form 10-K for Fiscal Year Ended March 28, 2015
Filed May 27, 2015
File No. 001 -35368
Definitive Proxy Statement on Schedule 14A
Filed June 16, 2015
File No. 001 -35368

Dear Mr. Idol :

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 will 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 Fiscal Year Ended March 28, 2015

Results of Operations, page 31

1. We note the statement on page 32 that  non-comparable store sales growth “was primarily
attributable to operating 121 additional stores since March 29, 2014 and sales from our e -
commerce  site.”  In future filings where you attribute material changes to multiple
reasons, please quantify the approximate proportion attributed to each reason.  Please
provide draft disclosure and confirm that future filings will address year -over-year
changes in e-commerce sales to the extent they are material to you.

John D. Idol
Michael Kors Holdings Ltd.
September 21 , 2015
Page 2

 Definitive Proxy Statement on Schedule 14A

2. We note the statement on page 28 that you purchased an aircraft for $16.5 million from a
related party.  However, we note the Aircraft Time Sharing Agreement s filed as Exhibit s
10.19 and 10.20, which appear to cover the personal use of the aircraft, state  that the
registrant is the “lessee” of the aircraft.  Please clarify in future filings the material terms
of the arrangement between you and the rel ated party from whom you acquired
possession, command and control of the aircraft.  In addition, please clarify the material
terms associated with the personal use of the aircraft.  Please provide draft disclosure .

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 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 provide  a written statement from the company
acknowledging that:

 the company i s responsible for the adequacy and accuracy of the disclosure 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 federal securities laws of the United States.

You may contact Jonathan Burr  at (202) 551 -5833  or James Lopez  at (202) 551 -3536
with any other question s.

Sincerely,

 /s/ James Lopez (for)

John Reynolds
Assistant Director
Office of Beverages, Apparel and
Mining

cc: Krista A. McDonough
 Vice President, Deputy General Counsel