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                             April 29, 2021

       Rustin Welton
       Chief Financial Officer
       Kontoor Brands, Inc.
       400 N. Elm Street
       Greensboro, NC 27401

                                                        Re: Kontoor Brands,
Inc.
                                                            Form 10-K for the
Fiscal Year Ended January 2, 2021
                                                            Filed March 3, 2021
                                                            File No. 001-38854

       Dear Mr. Welton:

              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 January 2, 2021

       Distribution Channels and Customers, page 5

   1.                                                   We note that you
operate 169 concession retail stores and that such arrangements typically
                                                        involve a dedicated
sales area within a retail location and payment of a concession fee for
                                                        use of the space based
on a percentage of retail sales. Please tell us if you recognize
                                                        concession sales on a
gross or net basis and explain how you assessed the guidance in
                                                        ASC 606-10-55-36
through -40 in determining the appropriate accounting treatment and
                                                        your role as principal
or agent. To the extent material, revise your revenue recognition
                                                        accounting policy in
future filings to discuss your concession retail arrangements.
       Exhibits and Financial Statement Schedules
       Exhibits 31.1 and 31.2, page 46

   2.                                                   Please amend your
filing to provide revised Exhibits 31.1 and 31.2 that read exactly as set
                                                        forth in Item
601(b)(31) of Regulation S-K.
 Rustin Welton
Kontoor Brands, Inc.
April 29, 2021
Page 2

       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 Melissa Gilmore at (202) 551-3777 or Andrew Blume at
(202) 551-
3254 with any questions.



FirstName LastNameRustin Welton                           Sincerely,
Comapany NameKontoor Brands, Inc.
                                                          Division of
Corporation Finance
April 29, 2021 Page 2                                     Office of
Manufacturing
FirstName LastName