March 16, 2022
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 3628
100 F Street, N.E.
Washington, D.C. 20549
| Re: | GUESS?, INC. Preliminary Proxy Statement on Schedule 14A Filed by Legion Partners Asset Management, LLC. |
Dear Sir or Madam:
We are writing in connection with the PREC14A filing made today by Legion Partners Asset Management, LLC (“Legion Partners Asset Management”) with respect to the 2022 annual meeting of stockholders of Guess?, Inc. (File No. 001-11893). We are acting as counsel to Legion Partners Asset Management. To the extent the Staff has any comments or questions with respect to the filing, please contact the undersigned.
| Best regards,
/s/ Elizabeth Gonzalez-Sussman Elizabeth Gonzalez-Sussman |