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                          April 23, 2021

       Laurent Mercier
       Chief Financial Officer
       COTY INC.
       350 Fifth Avenue
       New York, NY 10118

                                                        Re: COTY INC.
                                                            Form 10-K for the
Fiscal Year-Ended June 30, 2020
                                                            Form 8-K Filed
February 9, 2020
                                                            File No: 1-35964

       Dear Mr. Mercier:

              We have reviewed your March 29, 2021, response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       March 16, 2021, letter.

       Form 10-K for the Fiscal Year Ended June 30, 2020

       Note 5. Segment Reporting, page F-20

   1.                                                   We note your response
to comment 3 from our letter dated March 16, 2021. Please
                                                        address the following:
                                                            Provide us with
additional details about your management structure and how your
                                                            company is
organized. Briefly explain the nature of the organizational and
                                                            management changes
that accompanied the change in your segment reporting. Please
                                                            provide an
organization chart that captures the CEO and Chief Commercial Officer   s
                                                            (CCO) direct
reports to facilitate your explanations. Ensure you identify which of
                                                            your two CCOs is
your segment manager;
                                                            Describe the roles
and responsibilities of your CEO, your CCO, and other individuals
                                                            reporting directly
to your CEO;
 Laurent Mercier
COTY INC.
April 23, 2021
Page 2
                Describe the key operating decisions, who makes these
decisions, how performance
              is assessed and how resources are allocated within your business;
                Explain how you determined that your CEO is your CODM. In this
regard, we note
              from your response that your CCO is a single segment manager for
your three
              operating segments who reports to the CODM with responsibility
for operating
              activities, financial results, forecasts, and plans for the
segments. With reference to
              ASC 280-10-50-5, please explain why your CCO is not your CODM or
part of the
              CODM function. In your response, please compare and contrast the
roles and
              responsibilities of your CEO and CCO, and identify and briefly
describe the roles and
              responsibilities of other individuals reporting directly to your
CCO;
                Tell us how often the CEO meets with her direct reports, what
is typically discussed
              in those meetings, the financial information the CEO reviews in
conjunction with
              those meetings, and identify other participants at those
meetings;
                Explain how budgets are prepared, who approves the budget at
each step of the
              process, the level of detail discussed and individuals that
participate at each step, and
              the level at which the CEO makes changes to the budget; and
                Describe the basis for determining compensation for each
individual that reports to
              the CEO.



       You may contact Tracey McKoy, Staff Accountant, at (202) 551-3772 or,
Jeanne Baker,
Staff Accountant, at (202) 551-3691 or, Terence O'Brien, Accounting Branch
Chief, at (202)
551-3355 with any questions.



FirstName LastNameLaurent Mercier                               Sincerely,
Comapany NameCOTY INC.
                                                                Division of
Corporation Finance
April 23, 2021 Page 2                                           Office of Life
Sciences
FirstName LastName