July 23, 2008
VIA EDGAR
Mr. John Reynolds, Assistant Director
United States Securities and Exchange Commission
Division of Corporation Finance
100 F. Street N.E.
Washington, D.C. 205490-7010
| Re: | Urban Outfitters, Inc. Form 10-K for the fiscal year ended January 31, 2008 Filed March 28, 2008 File No. 000-22754 |
Dear Mr. Reynolds:
As our outside securities counsel has discussed with you, we respectfully request an extension of time to respond to the comment in your letter dated July 11, 2008 relating to the above referenced Form 10-K for the fiscal year ended January 31, 2008, filed with the SEC on March 28, 2008 (File No. 000-22754).
In light of scheduled vacations for key personnel, we are requesting this extension to allow us the additional time to consider the performance targets mentioned in the Staff’s comment and to perform an analysis of the impact of their possible disclosure on our company’s competitive position. As indicated to you, we intend to provide our response on or before August 15, 2008. Thank you for your consideration.
| Sincerely, |
| /s/ Glen A. Bodzy |
| Glen A. Bodzy, Esq. |
| Secretary and General Counsel |
| cc: | Glen T. Senk | |
| Walter J. Mostek, Esq. |