SecProbe.io

September 6, 2006

Mail Stop 3561

By Facsimile and U.S. Mail

Mr. Timothy J. O’Donovan
Chief Executive Officer
Wolverine World Wide, Inc.
9341 Courtland Drive
Rockford, Michigan 49351

Re: Form 10-K for the year ended December 31, 2005
 Filed March 15, 2006
 File No.  1-06024

Dear Mr. O’Donovan:

We reviewed your responses to our prior comments on the above referenced filing
as set forth in your letter dated August 29, 2006 and have the following additional
comments.  Please provide a written response to  our comments.  Please be as detailed as
necessary in your explanation.  In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure.  After reviewing this information, we may or  may not raise additional comments.

Form 10-K for the year ended December 31, 2005

Appendix A. Financial Statements

Consolidated Statements of Stockholders’ Equity and Comprehensive Income, page 2

1. We note your response to comment 3 of  our letter dated August 16, 2006.  You
indicated that the cost of treasury stock allocated to additional paid-in capital represented previous repurchases over par value on the same class of stock
included in additional paid-i n capital.  Please tell us  how you derived the amounts
previously included in additional paid-i n capital and how the amounts arose.  In
doing so, please clarify whether the amount s previously included in additional

Mr. Timothy J. O’Donovan
Wolverine World Wide, Inc. September 6, 2006
Page 2

paid-in capital represented capital surplus arising from previous retirements, net
gains on previous sales of treas ury stock or other amounts.

Consolidated Statements of Cash Flows, page 4

2. We note your response to comment 4 of our letter dated August 16, 2006.  Please
tell us the total amount of life insuran ce premiums paid and included in cash
flows from operating activities for each of the years pres ented.  Please also tell us
why life insurance premiums paid or the increase in cash surre nder value, if less
than premiums paid, are properly classifi ed as operating cash flows as opposed to
investing cash flows.  Please refer to  Section 1300.13 of The AICPA Technical
Practice Aids.  In addition, please tell us why purchase of trademarks is properly classified as operating cash flows as  opposed to investing cash flows.

 Please respond to these comments within 10 business days or tell us when you will provide us with a response.  Please furnish a letter that keys your responses to our
comments and provide any requested information.  Detailed letters gr eatly facilitate our
review.  Please understand that we may have  additional comments after reviewing your
responses to our comments.

 If you have any questions regarding these comments, please direct them to John
Cannarella, Staff Accountant, at  (202) 551-3337.  In his absence, direct your questions to
William Thompson at (202) 551-3334.  Any other questions may be directed to me at
(202) 551-3716.

Sincerely,

         William Choi
         A c c o u n t i n g  B r a n c h  C h i e f