August 27, 2018

Adam Ratner
Vice President, General Counsel and Secretary
New York & Company, Inc.
330 West 34th Street, 9th Floor
New York, New York 10001

       Re: New York & Company, Inc.
           Registration Statement on Form S-3
           Filed August 10, 2018
           File No. 333-226798

Dear Mr. Ratner :

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-3 filed August 10, 2018

Selling Stockholders, page 4

1.     The last two sentences in the first paragraph state: "[t]hese securities
are securities which
       were issued to directors, officers and employees from time to time
pursuant to equity
       incentive plans, or shares sold in our initial public offering or
subsequent secondary sale
       on January 25, 2006. In addition, Selling Stockholders may include
stockholders who in
       the aggregate hold less than 1% of our outstanding common stock."
However, the selling
       stockholder table reflects that the only selling stockholder is IPC/NYCG
LLC.
 Adam Ratner
New York & Company, Inc.
August 27, 2018
Page 2
      Please revise to clarify and describe the underlying transactions
regarding how
      IPC/NYCG LLC acquired the shares. In addition, please identify any
selling shareholders
      other than IPC/NYCG LLC.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Ronald (Ron) E. Alper at (202) 551-3329 or Brigitte
Lippmann at (202)
551-3713 with any other questions.



                                                           Sincerely,

FirstName LastNameAdam Ratner                              Division of
Corporation Finance
                                                           Office of Beverages,
Apparel and
Comapany NameNew York & Company, Inc.
                                                           Mining
August 27, 2018 Page 2
cc:       Christian O. Nagler
FirstName LastName