January 31, 2020

Brian Satenstein
Corporate Controller
Tapestry, Inc.
10 Hudson Yards
New York, NY 10001

       Re: Tapestry, Inc.
           Form 10-K for the Fiscal Year Ended June 29, 2019
           Filed August 15, 2019
           File No. 001-16153

Dear Mr. Satenstein:

      We have reviewed your filing and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your
disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 10-K for the Fiscal Year Ended June 29, 2019

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations, page 29

1.    Your narrative of the year-to-year fluctuations, in the summary and
segment performance
      sections, consistently use the phrase "excluding non-GAAP charges" to
refer to the
      expenses incurred for ERP implementation, integration and acquisition,
and the impact of
      the tax legislation that you excluded as adjustments in your GAAP to
Non-GAAP
      reconciliation. It appears to us that your use of this phrase may be
confusing to an investor
      since the items you are excluding are not non-GAAP charges, but rather
certain significant
      items affecting the comparability of your results of operations. Please
revise future filings
      to eliminate the use of the term "non-GAAP charges" where you discuss the
results of
      operations between periods, and characterize the nature of such charges
differently.
        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.
 Brian Satenstein
Tapestry, Inc.
January 31, 2020
Page 2

       You may contact Dale Welcome at 202-551-3865 or John Cash at
202-551-3768 with
any questions.



FirstName LastNameBrian Satenstein                    Sincerely,
Comapany NameTapestry, Inc.
                                                      Division of Corporation
Finance
January 31, 2020 Page 2                               Office of Manufacturing
FirstName LastName