Re: | Ulta Salon, Cosmetics & Fragrance, Inc. Form 10-K for the fiscal year ended January 30, 2010 Filed March 31, 2010 Forms 10-Q for the periods ended May 1, 2010, July 31, 2010, and October 30, 2010 Filed June 3, 2010, September 2, 2010, and December 2, 2010, respectively Definitive Proxy Statement on Schedule 14A Filed May 7, 2010 File No. 1-33764 |
1. | We read your response to comment five of our letter dated December 3, 2010. We note you do not believe that separate disclosure of salon services revenue would be beneficial to the readers of your financial statements. We do not concur with your conclusion. Please revise your future disclosure or advise us in detail why the readers of your financial statements would not find disclosure of the extent of services provided information useful or beneficial. |
2. | We read your response to comment 10 of our letter dated December 3, 2010. We believe the amounts charged to expense are significant and that you should include a tabular presentation of your reserve activity. Please confirm to us that you will present this information in future filings. |
| The Company is responsible for the adequacy and accuracy of the disclosure in this 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. |
Sincerely, |
||
/s/ Robert S. Guttman |
||
Robert S. Guttman |
||
Senior Vice President, General Counsel & Secretary
|