X0203 3 2011-02-09 0 0001166126 J C PENNEY CO INC JCP 0000904503 ROTH STEVEN C/O VORNADO REALTY TRUST 888 SEVENTH AVENUE NEW YORK NY 10019 1 0 0 0 Common Stock, par value $0.50 per share 23400000 I By VNO Fashion LLC and VSPS I L.L.C. Mr. Roth is a trustee and the Chairman of the Board of Trustees of Vornado Realty Trust ("Vornado"), which is the general partner of Vornado Realty L.P. ("VRLP"). VRLP is the sole member of VNO Fashion LLC and VSPS I L.L.C. Mr. Roth was elected to the board of directors of the Issuer on February 9, 2011. As a trustee of Vornado, Mr. Roth may be deemed to have a pecuniary interest in certain of the shares of the Issuer beneficially owned by Vornado. Mr. Roth disclaims any beneficial ownership of securities of the Issuer. /s/ Steven Roth 2011-02-09