February 5, 2025

Thomas J. Edwards, Jr.
Chief Financial Officer
Capri Holdings Limited
90 Whitfield Street, 2nd Floor
London, United Kingdom W1T 4EZ

       Re: Capri Holdings Limited
           Form 10-K for the Fiscal Year Ended March 30, 2024
           Form 8-K filed November 7, 2024
           File No. 001-35368
Dear Thomas J. Edwards Jr.:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       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.

Form 10-K for the Fiscal Year Ended March 30, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 52

1.     We note your disclosure that operating margin for the Versace segment
decreased
       from 13.7% for Fiscal 2023, to 2.4% for Fiscal 2024, primarily due to
increased retail
       store costs, increased marketing investments, deleveraging of operating
expenses on
       lower revenues and lower full price sell through compared to the prior
year. Please
       revise future filings to quantify the factors contributing to a change
such as this, and
       any significant change in a line item on the income statement,
especially when there is
       an offsetting amount. In this regard we also note your disclosure on
page 53 that the
       decrease in gross profit margin in fiscal 2024 was primarily
attributable to lower full
       price sell-through, partially offset by lower supply chain costs.
However, without
       quantification, we are unable to tell how significantly each factor
contributed to the
       change. Please revise accordingly and note that these changes should be
made to both
       the segment and consolidated discussions of your results of operations.
 February 5, 2025
Page 2


2.     We note that your disclosure on page 54 presents income from operations
for each
       segment and includes a subtotal that is titled    total income from
operations.    We
       further note that the amount presented on page 54 is not consistent with
the income
       from operations line item on the consolidated statements of operations
and
       comprehensive (loss) income. Please note that the presentation of the
total segment
       profit or loss measure outside of the ASC 280 required footnote
disclosure, would be
       considered a Non-GAAP financial measure and if presented in MD&A should
include
       the applicable non-GAAP disclosures required by Item 10(e) of Regulation
S-K.
       Please revise accordingly. These changes should also be applied to your
disclosure in
       your earnings release filed on Form 8-K.

Audited Financial Statements
Notes to the Audited Financial Statements
Note 4. Revenue Recognition, page 87

3.     We note that your disclosure of your revenue recognition policies
includes separate
       discussion of retail versus wholesale revenue. We also note that you
disclose that you
       have three primary channels of distribution: retail, wholesale and
licensing and your
       critical accounting estimates section of MD&A discloses that you have
separate
       reserves for wholesale and retail sales returns. We further note that
your disaggregated
       revenue disclosures include revenue by geographic location within each
segment and
       also by product category (as disclosed in Note 20). Please explain to us
how you
       considered the guidance in ASC 606-10-50-5, and ASC 606-10-55-89 through
55-91
       in determining whether or not to further disclose disaggregation of
revenue by
       amounts such as wholesale versus retail.


Form 8-K filed November 7, 2024
Exhibit 99.1 Earnings Release, page 1

4.     We note that in the bullet points at the top of your second quarter
earnings release,
       you disclose adjusted operating margin and adjusted earnings per share
without
       prominent disclosure of the most comparable GAAP amounts. Please note
that Item
       10(e)(1)(i)(A) of Regulation S-K requires that when you present a
non-GAAP
       measure, you must present the most directly comparable GAAP measure with
equal or
       greater prominence. Please revise accordingly. We also note that it does
not appear
       that you have presented a reconciliation of adjusted operating margin to
its most
       comparable GAAP measure within the earnings release which is required by
Item
       10(e)(1)(i)(B) of Regulation S-K. See additional guidance in Question
102.10(a) of
       the SEC Staff   s Compliance and Disclosure Interpretations on Non-GAAP
Financial
       Measures. Please revise future filings accordingly.

5.     We note your disclosure of free cash flow on the second page of your
earnings
       release. Please revise future filings to identify this measure as
non-GAAP and include
       the disclosures required by Item 10(e) of Regulation S-K.
 February 5, 2025
Page 3

        In closing, 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.

       Please contact Beverly Singleton at 202-551-3328 or Claire Erlanger at
202-551-3301
with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Manufacturing