SecProbe.io

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April 18, 2005

Mr. George F. Ohsiek, Branch Chief
Division of Corporate Finance
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

Mr. Ohsiek:
RE:      Wellco Enterprises, Inc.
         Form 10-K for the year ended July 3, 2004
         Filed October 1, 2004
         Forms 10-Q for the quarterly periods ended October 2, 2004 and January
         1, 2005 File No. 1-05555

Here is the response to your letter of March 16, 2005 commenting on the above
filings. The response is arranged and numbered in the sequence of your letter.

If additional information is needed, please let me know.

<PAGE>

Form 10-K for the Fiscal Year Ended July 3, 2004
------------------------------------------------

General
-------

1.       "Unless otherwise indicated, where a comment below requests additional
         disclosures or other revisions to be made, these revisions should be
         included in your future filings, as applicable."

         Responses to each item will address this point.

Cover Page
----------

2.       "In future filings, please revise to state the aggregate market value
         of voting and non-voting common equity held by non-affiliates as of the
         last business day of your most recently completed second fiscal
         quarter."

         Future filings will be changed to state something like the following:

                  As of August 31, 2XXX, 1,249,046 common shares (all voting)
                  were outstanding. The aggregate market value of the common
                  shares (based on the closing price of these shares on the
                  American Stock Exchange on December 31, 2XXX) of Wellco
                  Enterprises, Inc. held by nonaffiliates was approximately
                  $X,XXX,XXX.

Item 9A. Controls and Procedures
--------------------------------

(b) Changes in Internal Controls, page 6
----------------------------------------

3.       "Please refer to Item 308(c) of Regulation S-K and revise your
         disclosure to indicate whether there were "any changes," not just
         "significant" changes, in your internal control over financial
         reporting during your last fiscal quarter that materially affected, or
         are reasonably likely to materially affect your internal control over
         financial reporting."

         Future filings will be changed to state, assuming there are no changes
         that materially affected or are reasonably likely to materially affect
         internal controls over financial reporting, something like the
         following:

                  In the fourth quarter of the fiscal year 2XXXX, there were no
                  changes in internal controls over financial reporting that
                  materially affected, or are reasonably likely to materially
                  affect, the Company's internal control over financial
                  reporting.

         "Please also confirm to us supplementally that there were no changes in
         your internal control over financial reporting that occurred during the
         fourth quarter of fiscal 2004 that materially affected, or are
         reasonably likely to materially affect, your internal control over
         financial reporting."

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<PAGE>

         This confirms that there were no changes in our internal control over
         financial reporting that occurred during the fourth quarter of fiscal
         2004 that materially affected, or are reasonably likely to materially
         affect, our internal control over financial reporting.

2004 Annual Report
------------------

Management's Discussion and Analysis of Results of Operations and Financial
Condition
---------------------------------------------------------------------------

Results of Operations, page 4
-----------------------------

4.       "Throughout MD&A, you use the term "excess costs." Please clarify your
         disclosure to indicate exactly what this term means in the context of
         your discussion."

         Excess costs refer to costs not normally incurred to increase
         production to meet the boot demand for U. S. Armed Forces personnel
         serving in Iraq, and the costs to integrate a new boot into production.
         The majority of these costs would not have been incurred in fiscal year
         2004 if the factory rate of production prior to fiscal year 2004 was
         such that it could support the Iraq boot need, and if the factory had
         made the new boot prior to fiscal year 2004. These costs include new
         employee training costs, materials for production trials, boot testing,
         plant infrastructure costs and airfreight costs (as opposed to ocean
         freight) to ship materials for inventory build-up to the factory in
         Puerto Rico.

         In future filings, the use of "excess costs" will be followed by
         examples of such costs.

Liquidity and Capital Resources, page 12
----------------------------------------

5.       "Your presentation of income before depreciation and other non-cash
         adjustments represents a non-GAAP measure subject to the disclosure and
         reconciliation requirements of Item 10(e) of Regulation S-K. Based on
         the context of your disclosure, we assume this measure is intended as
         liquidity and not a performance measure. If our assumption is
         incorrect, please advise. Otherwise, please revise your disclosure as
         follows:

         (a)     identify this measure as a non-GAAP liquidity measure;
         (b)     provide a detailed reconciliation to cash flows from operating
                 activities;
         (c)     indicate the substantive reasons why you believe presentation
                 of this non-GAAP measure provides useful information to
                 investors, and
         (d)     disclose how management uses this non-GAAP measure.

         Additionally, please present cash flows from investing and financing
         activities alongside this non-GAAP liquidity measure. See Question 12
         of the Frequently Asked Questions Regarding the Use of Non-GAAP
         Financial Measures issued on June 13, 2003, which is available on our
         website, www.sec.gov."

         Instead of presenting non-GAAP measures, we propose to present only
         GAAP measures. This presentation would start with cash from operations
         as one number, followed by one number for each of investing and
         financing cash. Below this presentation, we would discuss the major

PAGE 3 OF 7
<PAGE>

         components affecting each of these components of GAAP cash flow. Please
         let us know if you have a comment on this presentation.

6.       "Please consider revising your contractual obligations table to
         include:

         (a)     Interest payments on your debt; and
         (b)     Required and planned funding of your pension and retiree health
                 benefits plans.

         Because the table is aimed at increasing transparency of cash flow, we
         believe these payments should be included in the table. If you chose
         not to include these payments, a footnote to the table should clearly
         identify the excluded item(s) and provide any additional information
         that is material to understanding your cash requirements. See Item
         303(a)(5) of Regulation S-K and footnote 46 to SEC Release No.
         33-8350."

         We propose to supplementally disclose immediately below the one you are
         referring to that would show for the most recent fiscal year material
         cash payments for:

         (a)     Interest.
         (b)     Pension plan funding.
         (c)     Retiree health benefit funding. This retiree benefit only
                 covers early retirees (ages 62-65 who have completed at least
                 10 years of service) and disabled retirees. This benefit stops
                 when the person qualifies for Medicare. In many years, the
                 cash used for this benefit is not material. When it is
                 material, we will disclose.
         (d)     Footnote 46 also refers to taxes. We will also evaluate the
                 materiality of cash used to pay income taxes and will disclose
                 as appropriate.

         As to planned funding, we will make a statement as to whether, based on
         information know as of the date of filing, we expect future cash
         requirements for the disclosed items to approximate the historical
         numbers shown.

Financial Statements
--------------------

Notes to Consolidated Financial Statements
------------------------------------------

2. Summary of Significant Accounting Policies, page 20
------------------------------------------------------

General
-------

7.       "Please  disclose  the  types of  expenses  that you  include  in the
         cost of sales  and  services  line item and the types of expenses
         that you include in the general and  administrative  expenses line
         item.  In doing so, please  disclose  specifically whether you include
         inbound freight charges,  purchasing and receiving costs,  inspection
         costs,  warehousing costs,  internal transfer  costs and the other
         costs of you  distribution  network in cost of sales and services.  If
         you  currently  exclude a significant  portion of these costs from cost
         of sales and services,  please  provide  cautionary  disclosure in MD&A
         that you gross margins may not be comparable to others,  since some
         entities  include the costs related to their  distribution  network

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<PAGE>

         in cost of sales and services and others like you exclude all or a
         portion of them from gross margin,  including  them instead in a line
         item such as general and  administrative  expenses.  To the extent the
         excluded costs are material to your operating results,  quantify  these
         amounts in MD&A.  If you  determine  that these  amounts are immaterial
         for  disclosure,  please supplementally provide us with you qualitative
         and quantitative assessment of materiality for all periods presented."

         In future filings, we will replace "Shipping and Handling Costs" with
         the caption "Cost of Sales and Services" and will state something like
         the following:

                  Cost of sales and services includes raw materials and
                  freight-in on raw materials, direct and indirect manufacturing
                  labor, employee fringe benefits on manufacturing labor,
                  manufacturing supplies, purchasing and receiving costs,
                  material inspection costs, warehousing costs, internal
                  transfer costs, product distribution costs including shipping
                  and handling, repairs and maintenance, supervisors salaries,
                  depreciation on manufacturing equipment, and other
                  manufacturing overhead costs. Any amounts paid by customers
                  for shipping and handling costs incurred are included in
                  Revenues.

         In future filings, we will include the caption "General and
         Administrative Expenses" in Note 2, probably immediately after the
         above section, and will state something like the following:

                  General and Administrative Expenses include administrative
                  personnel compensation costs, legal and audit costs,
                  depreciation on administrative equipment, stock expense and
                  director fees, travel costs, office supplies, and other such
                  costs not directly related to the manufacture of the Company's
                  products. Since the majority of its products are sold to the
                  U. S. government, the Company does not incur significant
                  selling costs, such as sales commissions and advertising.

9. Pension Plans, page 26
-------------------------

8.       "Please disclose your investment policies and strategies, including
         target allocation percentages or range of percentages for each major
         category of plan assets. Additionally, please disclose the basis used
         to determine the overall expected long-term rate-of-return-on assets
         assumption. Refer to paragraphs 5.d.(2) and 5.d.(3) of SFAS 132(R)."

         Future filings will include disclosure in Note 9 similar to the
         following:

                  The Company target for investment diversification of the plan
                  assets for both defined benefit pension plans is 45% equities
                  and 55% fixed income. If actual investments levels are 2%
                  different than these targets, adjustments to the investment

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<PAGE>

                  funds are made. The target portfolio mix of these investments
                  at December 31, 2004 is:

                  --------------------------------------------------------------
                  New England Financial Large Cap Core                    29.0%
                  --------------------------------------------------------------
                  New England Financial Small Cap                          8.0%
                  --------------------------------------------------------------
                  Templeton Foreign                                        8.0%
                  --------------------------------------------------------------
                  Total Equities                                          45.0%
                  --------------------------------------------------------------
                  Loomis Sayles Core Bond Fund                             5.0%
                  --------------------------------------------------------------
                  New England Financial General Investment Account        50.0%
                  --------------------------------------------------------------
                  Total Fixed Income                                      55.0%
                  --------------------------------------------------------------

                  This allocation and investment funds was selected as one that
                  limits risk while providing higher returns on plan assets then
                  guaranteed rate funds, while still providing adequate
                  liquidity to meet payments to retirees.

                  In developing the assumed weighted-average long-term rate of
                  return on plan assets, the Company used information from its
                  third party pension plan assets manager, including their
                  review of asset class return expectations and long-term
                  inflation assumptions. Also considered in setting this rate is
                  the historical return on plan assets.

9.       "Please disclose the measurement date(s) used to determine the pension
         and other retiree health benefit measurements. See paragraph 5.k. of
         SFAS 132(R)."

         Future filings will include disclosure in Notes 9 and 10 similar to the
         following:

                  Benefit measurements for pension (retiree health care) plan(s)
                  is June 30, 2004.

22. Subsequent Event, page 40
-----------------------------

10.      "Please confirm to us supplementally that it has been your consistent
         accounting policy to record reimbursements under the Puerto Rico
         government program in the fiscal period in which the reimbursements are
         received. Also help us understand why it is your policy to record these
         payments on a cash basis, rather than accruing th