July 11, 2025
Adam Orvos
Executive Vice President and Chief Financial Officer
Ross Stores, Inc.
5130 Hacienda Drive
Dublin, CA 94568
Re: Ross Stores, Inc.
Form 10-K for Fiscal Year Ended February 1, 2025
Response dated June 30, 2025
File No. 000-14678
Dear Adam Orvos:
We have reviewed your June 30, 2025 response to our comment letter and
have the
following comment(s).
Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our June 17,
2025 letter.
Form 10-K for Fiscal Year Ended February 1, 2025
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 26
1. We note your response to comment 1. You state the principal drivers for
variances are
presented in order of significance. While listing factors in order of
magnitude is not
objectionable in and of itself, it is an indirect and less useful way to
provide needed
information to your investors. Your intended, revised disclosure
continues to either
not quantify certain factors at all or to quantify them in an indirect
manner, such as by
references to percentages of other percentages. We believe you should
make it easy
for investors to obtain quantified impacts of factors, by stating them
in absolute
dollars. Refer to Instruction 3 to S-K 303(b). Please revise to quantify
material factors
in absolute dollars and provide us a copy of your intended, revised
disclosure.
July 11, 2025
Page 2
Regarding the impacts of changes in price and volume on revenue, we note
your
proposed attribution to traffic (volume-driven) and basket (volume- and
price-driven)
because goods sold vary from period to period. We acknowledge that
isolating
reasons for specific material changes, and quantifying such isolated
reasons, can
sometimes be challenging because they can be highly interrelated. In
such
circumstances, we encourage you to acknowledge this fact, and to explain
such
interrelated circumstances to the extent possible. To the extent you do
implement changes in price across your assortment that materially
impacts sales, we
encourage you to describe and quantify the impact of the change.
Please contact Patrick Kuhn at 202-551-3308 or Lyn Shenk at 202-551-3380
if you
have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services