May 29, 2019

Phillip Watts
Co-Principal Financial Officer and Principal Accounting Officer
DILLARD'S, INC.
1600 Cantrell Road
Little Rock, Arkansas 72201

       Re: DILLARD'S, INC.
           Form 10-K for the Fiscal Year Ended February 2, 2019
           Filed March 29, 2019
           File No. 001-06140

Dear Mr. Watts:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

Form 10-K for the Fiscal Year Ended February 2, 2019

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Key Performance Indicators, page 19

1.    Please tell us if online sales are are included in the retail stores
sales trend
      percentages, comparable retail store sales trend percentages and your
definition of
      comparable store sales in the description of Net sales under the General
heading on page
      20. Also, please quantify for us the effect that online sales had on your
net sales and gross
      profit for the years presented and tell us the trend in online sales
during the past three
      years. Refer to Item 303(a)(3)(ii) of Regulation S-K.
Financial Statements
Note 1. Description of Business and Summary of Significant Accounting Policies
Revenue Recognition, page F-11

2.    We note your Retail Operations segment recognizes merchandise revenue at
the point of
 Phillip Watts
DILLARD'S, INC.
May 29, 2019
Page 2
         sale; however, we also note your disclosure in the first paragraph on
page F-13 that there
         is some deferral of revenue related to internet sales. Please tell us
your consideration of
         disclosing your revenue recognition policy related to internet sales.
Also, please tell us
         and revise to clarify if revenue from private label cards is
recognized over time or at a
         point in time. In addition, please clarify the methods used to measure
progress, if
         applicable, and why the methods reflect a faithful depiction of the
transfer of the goods
         and services. Reference ASC 606-10-50-18 and 19.
       In closing, 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.

      You may contact Tony Watson (Staff Accountant) at (202)-551-3318 or Bill
Thompson
(Accounting Branch Chief) at (202) 551-3344 with any questions.



FirstName LastNamePhillip Watts                                Sincerely,
Comapany NameDILLARD'S, INC.
                                                               Division of
Corporation Finance
May 29, 2019 Page 2                                            Office of
Consumer Products
FirstName LastName