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January 25, 2023
David Foulkes
Chief Executive Officer
Brunswick Corporation
26125 N. Riverwoods Blvd., Suite 500
Mettawa, IL 60045-3420
Re:Brunswick Corporation
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed February 16, 2022
File No. 001-01043
Dear David Foulkes:
            We have reviewed your January 3, 2023 response to our comment letter 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.  Unless we note otherwise, our references to prior comments are to comments in our
December 16, 2022 letter.
Form 10-K for Fiscal Year Ended December 31, 2021
Notes to Consolidated Financial Statements
Note 6. Segment Information, page 73
1.Your response dated December 5, 2022 explains that separate individuals are responsible
for the Engine P&A and ASG operating segments.  Beyond having separate segment
managers to increase focus within each of these operating segments, tell us why Engine
P&A and ASG are organized as separate operating segments for purposes of allocating
resources and assessing performance.

 FirstName LastNameDavid Foulkes
 Comapany NameBrunswick Corporation
 January 25, 2023 Page 2
 FirstName LastName
David Foulkes
Brunswick Corporation
January 25, 2023
Page 2
2.You state in your December 5, 2022 response that operating margin “is the primary
measure of profitability used by the CODM for allocating resources and assessing
performance.”  We also note your disclosure on page 74 of your 2021 Form 10-K that
“[t]he Company evaluates performance based on segment operating earnings.”  Please
address the following:
•Identify what measures of segment profit or loss are reviewed by the CODM for
assessing segment performance and deciding how to allocate resources.  In addition,
if your CODM uses more than one measure of segment profit or loss, tell us if each
of those measures have been considered as part of your assessment of whether Engine
P&A and ASG have similar economic characteristics.
•The measure of operating margin from the quantitative information provided in your
January 3, 2023 response letter appears to differ from the non-GAAP measure of
Adjusted Operating Earnings as disclosed in your December 31, 2021 Form 10-K.
Please identify and explain the difference in such measures.
•Tell us the extent to which, and underlying reasons why, any of the adjustments to
operating margin referenced in your December 5, 2022 response are applicable to one
operating segment versus the other with accompanying quantification.
•Provide us with segment operating earnings consistent with the measure disclosed on
page 74 of your December 31, 2021 Form 10-K for Engine P&A and ASG and an
analysis of economic similarity for each historical and forecasted period considered
in your other analyses.
3.In response to prior comment 2, you refer to your evaluation of revenue trends for the
Engine P&A and ASG operating segments.  Please further describe this evaluation and
explain how the particular factors underlying the differences in revenue growth rates
between these segments were considered in your analysis of economic similarity.
4.Your response to comment 2 indicates that your Engine P&A and ASG operating
segments sell a portfolio of products that include several of the exact same parts (e.g., boat
seats).  It appears the segments also sell products that are different (e.g., crankshafts for
Engine P&A and lithium-ion batteries for ASG).  Please provide us with a detailed
breakdown of sales by product category for each of these segments for each of the three
most recent fiscal years along with an explanation of the products within each category.
In addition, tell us how your assessment of similar economic characteristics for these
segments considered any differences in sales by product category.
5.Your December 5, 2022 response indicates the extent to which each of your Engine P&A
and ASG segment’s operations are related to distribution, with the remainder being
manufacturing.  Please provide an overview of your distribution and manufacturing
operations for each segment, tell us the reasons for any difference in the mix of
distribution and manufacturing, and how it was considered in your assessment of
similarity of the nature of production processes.

 FirstName LastNameDavid Foulkes
 Comapany NameBrunswick Corporation
 January 25, 2023 Page 3
 FirstName LastName
David Foulkes
Brunswick Corporation
January 25, 2023
Page 3
6.Provide us with a breakdown of external sales by type of customer (e.g., big box retailers,
authorized dealers, original equipment manufacturers, aftermarket channels, etc.) and
sales to other operating segments of the Company for each of Engine P&A and ASG for
each of the three most recent fiscal years.  Please also indicate what percentage of sales
for these periods are to the same customers.  Include your analysis of differences in type
of customer between the two operating segments.
            You may contact Chen Chen, Staff Accountant, at 202-551-7351 or Kathleen Collins,
Accounting Branch Chief at 202-551-3499 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Ryan M. Gwillim