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No. of Recommendations: 3
after looking clothing and restaurant retail over the last year or so, it seemed like revenue growth usually closely paralleled store growth plus comps. More than a few seemed to have revenue growth that was very nearly comps+store growth percentage.

Looking at Ulta, they rarely have revenue growth that is even close to comps plus percentage growth in stores. It almost always lags by several percentage points.

growth

Q3/13 Q2/13 Q1/13 Q4/12 Q3/12 Q2/12 Q1/12 Q4/11
======================================================================
revenue 22.4% 24.8% 22.9% 30.3% 22.4% 22.1% 22.8% 23.0%
comps +
store growth 28.75% 31.64% 28.64% 30.49% 29.89% 27.13% 28.63% 26.92%


my read is that new stores aren't making as much as old stores but the company doesn't report aws or honeymoon sales so it's hard to know what the non-comp store base is doing. Maybe the stores that are not comps yet but not new are not doing all that well either. Any ideas?

The SEC is asking about the Q4 2012. They thought the 30% growth in revenue was uncharacteristic and needed explanation. I thought it looked like the way things usually go in retail since it was close to comps plus new stores, but then I noticed they never do this in any other quarter. Any idea what may be going down here?

We further note that your fourth quarter 2012 sales grew 30%, however your disclosure does not address the factors that lead to this significant increase. Please provide draft disclosure to be included in future filings that expands MD&A to discuss all of the factors that contributed to the 2012 full year and fourth quarter results. Further explain your statement on page 31 that you do not expect your 8.8% fiscal 2012 comparable store sales increase to continue into the future.
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