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April 29, 2005

Mr. Michael Moran

Branch Chief

U. S. Securities & Exchange Commission

450 Fifth Street N.W.

Washington, DC 20549

    RE:

    Weyco Group, Inc.

    Form 10-K for the fiscal year ended December 31, 2004

    File No. 0-9068

Dear Mr. Moran:

     Thank you for your prompt review of our Form 10-K for the fiscal year ended December 31, 2004.
We have reviewed your comment letter dated March 30, 2005. Our response to each of your comments
follows:

Form 10-K for the fiscal year ended December 31, 2004

Management’s Discussion and Analysis (MD&A) of Financial Condition and Results of
Operations

Results of Operations

    1.
    In future filings please include a tabular presentation of net sales revenues by brand
for the periods presented and provide a narrative discussion of the extent
to which material changes are attributable to pricing, mix or volume of goods sold. Please
refer to SEC Release No. 33-8350 and Item 303(a)(3)(iii) of Regulation S-K.

    Response:

In future filings we will include a tabular presentation of net sales by brand for the
periods presented. We will also provide a narrative discussion of material changes
attributable to pricing, mix, volume of goods sold or new products in accordance with
303(a)(3)(iii) of Regulation S-K. The table and narrative, which we will begin presenting
in our Form 10-Q for the quarter ending March 31, 2005, will be similar to the following:

Mr. Michael Moran

U.S. Securities & Exchange Commission

Page 2 of 11

Wholesale Sales

    Three months ended March 31,

    2005

    2004

    % change

    Stacy Adams

    $
    17,147,179

    $
    17,509,780

    -2.1
    %

    Nunn Bush

    17,781,087

    21,672,092

    -18.0
    %

    Florsheim

    13,336,562

    14,221,786

    -6.2
    %

    Foreign

    1,618,807

    1,136,989

    42.4
    %

    Total

    $
    49,883,635

    $
    54,540,647

    -8.5
    %

    The performance of the Stacy Adams brand was comparable between periods. The 18%
decline in first quarter net sales of the Nunn Bush brand reflects the challenging retail
environment in the moderately priced men’s footwear market. Additionally, the Company is
going through some product transitions with some of its major accounts. Net sales of the
Florsheim brand decreased 6.2% in comparison to the prior year period. During the quarter,
the Company made the decision to discontinue the FLS product line in the United States. FLS
is a lower priced sub brand in the Florsheim division. Sales of FLS were down $1.1 million
or 51% for the quarter. Sales of all other Florsheim products increased 3% in the quarter.
The Company estimates that the effect on total Florsheim sales resulting from the
discontinuance of FLS will be $5-$6 million for 2005.

Liquidity and Capital Resources

    2.
    Please advise us and revise future filings to describe your inventory and other
purchase obligations in a footnote to the contractual obligations table. Also, please
explain why there was a buildup of inventory in 2004.

    Response:

We will describe our purchase obligations in a footnote to the contractual obligations table
in our future Form 10-K filings, substantially, as follows:

    Purchase obligations relate entirely to commitments to purchase inventory under legally
enforceable contracts with defined terms as to price, quantity and delivery.

    With regard to the “buildup of inventory in 2004”, we included the following explanation in
the below referenced filings throughout fiscal 2004:

    Form 10-K for the fiscal year ended December 31, 2004

    Item 7: MD&A — Liquidity & Capital Resources:

“Higher net earnings in the current year were more than offset by the buildup of
inventory in 2004 from unusually low levels at December 31, 2003.”

Mr. Michael Moran

U.S. Securities & Exchange Commission

Page 3 of 11

    Form 10-Q for the period ended September 30, 2004

    Item 2: MD&A — Liquidity & Capital Resources:

        . . .“while the increase in inventory was attributable to the Company’s efforts to buildup
inventory from unusually low levels at December 31, 2003.”

    Form 10-Q for the period ended June 30, 2004

    Item 2: MD&A — Liquidity & Capital Resources:

“This was primarily due to a buildup of inventory in the second quarter of 2004 to cover
increased bookings.”

    In our future Form 10-K filings, we will include language to explain that the buildup of
inventory in 2004 was due to increased bookings. Additionally, we will address any future
material inventory changes in a separate paragraph within the “Liquidity & Capital
Resources” section of the MD&A.

Critical Accounting Policies

    3.
    In future filings, please review your disclosure to present critical accounting
policies within MD&A. Such disclosure should supplement, not duplicate, the description of
accounting policies that are already disclosed in the notes to the financial statements.
The disclosure should provide greater insight into the quality and variability of
information regarding financial condition and operating performance. The discussion in MD&A
should present your analysis of the uncertainties involved in applying a principle at a
given time or the variability that is reasonably likely to result from its application over
time.

    •
    Discuss why management believes the accounting policy is critical;

    •
    Discuss how accurate your estimates and assumptions have been in the past, how much
they have changed in the past and whether they are likely to change in the future;

    •
    Include quantitative disclosure of your sensitivity to change based on other
outcomes that are reasonably likely to occur and that would have a material effect on
the company.

    For example, for your “Revenue Recognition” policy, you could discuss the
provision for sales returns and allowance for doubtful accounts both on a total
cost basis as well as on a percentage of revenues. Your discussion could further
address variances that have occurred in historic results, trends and future
expectations, as well as the impact to the statement of operations resulting from
hypothetical changes. Refer to Item V of Release Nos. 33-8350/34-48960.

Mr. Michael Moran

U.S. Securities & Exchange Commission

Page 4 of 11

    Response:

Based on the high level of estimates and judgment involved, we have determined that our
critical accounting policies are the recovery of accounts receivable as well as the
determination of liabilities related to pension benefits. We discussed the uncertainties
involved with these two critical accounting policies and provided quantitative information
with regard to changes in assumptions within the MD&A of our Form 10-K for the fiscal year
ended December 31, 2004 as follows:

    OTHER

Critical Accounting Policies

    The Company’s accounting policies are more fully described in Note 2 of the Notes to
Consolidated Financial Statements. As disclosed in Note 2, the preparation of financial
statements in conformity with accounting principles generally accepted in the United States
of America requires management to make estimates and assumptions about future events that
affect the amounts reported in the financial statements and accompanying notes. Future
events and their effects cannot be determined with absolute certainty. Therefore, the
determination of estimates requires the exercise of judgment. Actual results inevitably
will differ from those estimates, and such differences may be material to the financial
statements.

    The most significant accounting estimates inherent in the preparation of the Company’s
financial statements include estimates as to the recovery of accounts receivable, as well as
those used in the determination of liabilities related to pension benefits. The allowances
for sales returns and doubtful accounts are fact-specific and take into account such factors
as specific customer situations, historical experience and current and expected economic
conditions. Changes in these allowances may be required if actual returns, discounts and
bad debt activity varies from the original estimates.

    The pension benefit obligation and pension expense are calculated in accordance with SFAS
No. 87, “Employers’ Accounting for Pensions,” and are impacted by certain actuarial
assumptions, including the discount rate and the expected rate of return on plan assets.
These rates are evaluated on an annual basis considering such factors as market interest
rates and historical asset performance. Actuarial valuations at December 31, 2004, used a
discount rate of 5.75% and an expected rate of return on plan assets of 8.5%. A 0.5%
decrease in the discount rate would increase annual pension expense by approximately
$39,000. A 0.5% decrease in expected return on plan assets would increase annual pension
expense by approximately $117,000.

    In future Form 10-K filings, we will expand our Critical Accounting Policies disclosure in
MD&A further to state: (expanded language is bolded)

Mr. Michael Moran

U.S. Securities & Exchange Commission

Page 5 of 11

    OTHER

Critical Accounting Policies

    The Company’s accounting policies are more fully described in Note 2 of the Notes to
Consolidated Financial Statements. As disclosed in Note 2, the preparation of financial
statements in conformity with accounting principles generally accepted in the United States
of America requires management to make estimates and assumptions about future events that
affect the amounts reported in the financial statements and accompanying notes. Future
events and their effects cannot be determined with absolute certainty. Therefore, the
determination of estimates requires the exercise of judgment. Actual results inevitably
will differ from those estimates, and such differences may be material to the financial
statements. The following policies are considered by management to be the most critical in
understanding the significant accounting estimates inherent in the preparation of the
Company’s financial statements and the uncertainties that could impact the Company’s results
of operations, financial position and cash flows.

    Allowances for Sales Returns and Doubtful Accounts

The Company records allowances for sales returns and doubtful accounts for losses resulting
from accounts receivable balances that will ultimately not be collected. The allowances are
based on such factors as specific customer situations, historical experience, a review of
the current aging status of customer receivables and current and expected economic
conditions. The allowances include a specific reserve for accounts identified as
potentially uncollectible, plus a general reserve for the balance of accounts. The Company
evaluates the allowances and the estimation process on at least a quarterly basis and makes
adjustments when appropriate. Historically, losses have been within the Company’s
expectations. Changes in these allowances may be required if actual returns, discounts and
bad debt activity varies from the original estimates. These changes could impact the
Company’s results of operations, financial position and cash flows.

    Pension Plan Accounting

The Company accounts for its defined benefit pension plans in accordance with SFAS No. 87,
“Employers’ Accounting for Pensions.” See Note 10 of the Notes to Consolidated Financial
Statements for further discussion of these plans. The calculation of pension expense and
the corresponding obligation require certain actuarial assumptions. Management believes the
two most critical of these assumptions are the discount rate and the expected rate of return
on plan assets. The Company evaluates its actuarial assumptions annually on the measurement
dates (December 31) and makes modifications based on such factors as market interest rates
and historical asset performance. Changes in these assumptions can result in different

Mr. Michael Moran

U.S. Securities & Exchange Commission

Page 6 of 11

    expense and liability amounts, and future actual experience can differ from these
assumptions.

    Discount Rate – Pension expense and projected benefit obligation both increase as the
discount rate is reduced. The discount rate used by the Company is based on the current
interest rates earned on high quality long-term bonds. The Company utilized a discount rate
of X.X%, 5.75% and 6.0% at December 31, 2005, 2004 and 2003, respectively. The decline in
2004 was consistent with changes in published bond indices at those dates. For fiscal 2005,
a 0.5% decrease in the discount rate would increase annual pension expense and projected
benefit obligation by approximately $XX,000 and $XXX,000, respectively.

    Expected Rate of Return — Pension expense increases as the expected rate of return on
pension plan assets decreases. In estimating the expected return on plan assets, the
Company considers the historical returns on plan assets and future expectations of asset
returns. The expected rate of return on plan assets of 8.0% for fiscal 2005 was based on
the Company’s long-term investment policy of equity securities: 20% — 100%; fixed income
securities: 80% — 20%; and other, principally cash 0% — 20%. For fiscal 2005, 0.5% decrease in
the expected return on plan assets would increase annual pension expense by approximately
$XXX,000.

    The Company’s pension expense in 2005, 2004 and 2003 was $XXX,000, $713,000 and
$992,000, respectively.

Consolidated Financial Statements and Notes to Consolidated Financial Statements

Note 2. Summary of Significant Accounting Policies

Principles of Consolidation

    4.
    Please advise us and revise future filings to disclose the principles you follow for
including or excluding subsidiaries in the consolidated financial statements. See Rule
3A-03 of Regulation S-X.

    Response:

All of the Company’s subsidiaries are included in the consolidated financial statements as
they are all 100% owned. We will revise this section of our future Form 10-K filings to
read:

    Principles of Consolidation — The consolidated financial statements are prepared in
conformity with accounting principles generally accepted in the

Mr. Michael Moran

U.S. Securities & Exchange Commission

Page 7 of 11

    United States of America and include the accounts of Weyco Group, Inc. and all domestic and
foreign subsidiaries.

Cost of Sales

    5.
    Please disclose the types of expenses that you include in the cost of sales line
item and the types of expenses that you include in the selling, general and administrative
expenses line item in addition to shipping and handling. In doing so, please disclose
specifically whether you include inbound freight charges, receiving costs, inspection costs,
warehousing costs, internal transfer costs and the other costs of your distribution network
in cost of sales. If you currently exclude a significant portion of these costs from costs
of sales, please provide cautionary disclosure in MD&A that your gross margins may not be
comparable to others, since some entities include the costs related to their distribution
network in cost of sales and others like you exclude all or a portion of them from gross
margin, including them instead in a line item such as selling, general and administrative
expenses. To the extent it would be material to an investor’s ability to compare your
operating results to others in your industry, quantify in MD&A the amount of these costs
excluded from cost of sales.

    Response:

Beginning with our Form 10-Q for the period ending March 31, 2005, we will include
disclosures in our MD&A similar to the following:

    Results of Operations

    The Company’s cost of sales does not include distribution costs (e.g., receiving, inspection
or warehousing costs). The Company’s distribution costs of $1,114,000 and $1,234,000 for
the three months ended March 31, 2005 and 2004, respectively, were included in selling and
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