| 140 Scott Drive | ||
| Menlo Park, California 94025 | ||
| Tel: +1.650.328.4600 Fax: +1.650.463.2600 | ||
| www.lw.com | ||
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| FIRM / AFFILIATE OFFICES | ||
| Barcelona |
| New Jersey |
| Brussels |
| New York |
| Chicago |
| Northern Virginia |
| Frankfurt |
| Orange County |
| Hamburg |
| Paris |
| Hong Kong |
| San Diego |
May 14, 2008 | London |
| San Francisco |
| Los Angeles |
| Shanghai |
| Madrid |
| Silicon Valley |
| Milan |
| Singapore |
| Moscow |
| Tokyo |
John Reynolds, Assistant Director | Munich |
| Washington, D.C. |
Office of Beverages, Apparel and Health Care Services |
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United States Securities and Exchange Commission | File No. 039215-0005 | ||
Division of Corporation Finance |
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100 F Street, N.E. |
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Washington, D.C. 20549-3628 |
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Re: | bebe stores, inc. | |
| Form 10-KSB for Fiscal Year Ended July 7, 2007 | |
| File No. 0-24395 |
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Dear Mr. Reynolds:
On behalf of bebe stores, inc. (the “Company”), we are hereby filing this letter to address a verbal comment received from the Staff of the Securities and Exchange Commission (the “Commission”).
Schedule 14A
Compensation Discussion and Analysis, page 10
Response: In response to the Staff’s comment, in its fiscal 2008 Compensation Discussion and Analysis the Company will provide a quantitative discussion of the terms of the necessary targets for the Company’s named executive officers necessary to be achieved to earn cash incentive bonuses and performance-based restricted stock unit bonuses. For fiscal 2008, the Company will not seek to omit any specific targets pursuant to Instruction 4 to Item 402(b) of Regulation S-K.
* * *
I hope the foregoing answers are responsive to your comments. Please do not hesitate to contact me by telephone at (650) 463-3060 or by fax at (650) 463-2600 with any questions or comments regarding this correspondence.
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| Very truly yours, |
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| /s/ Tad J. Freese |
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| Tad J. Freese |
| of LATHAM & WATKINS LLP |
| cc: | Susann Reilly |
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| Walter Parks |
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| Larry Smith |