January 8, 2020 Thomas B. Heacock Chief Financial Officer The Buckle, Inc. 2407 West 24th Street Kearney, Nebraska 68845 Re: The Buckle, Inc. Form 10-Q for the Fiscal Quarter Ended November 2, 2019 Filed December 12, 2019 File No. 001-12951 Dear Mr. Heacock: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Trade & Services