SecProbe.io

December 22, 2011
 Via E-mail

Donald T. Grimes Chief Financial Officer Wolverine World Wide, Inc.
9341 Courtland Drive N.E.
Rockford, Michigan 49351
Re: Wolverine World Wide, Inc.
 Form 10-K for Fiscal Year Ended January 1, 2011
Filed March 2, 2011 File No. 001-06024

Dear Mr. Grimes:
 We have reviewed your filing 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for Fiscal Year Ended January 1, 2011

 Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations, page 24
 Results of Operations, page 25

 1. Throughout this section, you often use the word  “primarily” or refer to two or more
factors that contributed to ma terial changes over the report ed periods.  For example, you
state “strong organic growth in unit volume and higher average selli ng price for the brand
footwear, apparel and licensing operations resulted in $122.1 million of the increase” in
revenue.  Also, you state that the increase in gross margin was “primarily resulted from
restructuring and other transition costs…”  In future filings, please quantify the amount of the changes contributed by each of the factors or events th at you identify.  See Section
III.D of SEC Release 33-6835 (May 18, 1989).

Donald T. Grimes Wolverine World Wide, Inc. December 22, 2011 Page 2

2. We note your general discussion in results of ope ration on lower foreign tax rates.  In this
regard, we note the trend in your earnings be fore taxes from forei gn affiliates and your
provision for foreign income taxe s.  Please provide additional disclosures that explain in
greater detail the impact on your effective income tax rates and obligations of having
earnings in countries where you have lower statut ory tax rates.  To the extent that certain
countries have a more significant impact on your  effective tax rate, then tell us how you
considered clarifying this information and including a discussion regarding how potential
changes in such countries’ operations or the tax environment may impact your results of
operations.  Please discuss the material tre nds and uncertainties in the increases in
nontaxable earnings in foreign affiliates.  Please provide us with the text of proposed
disclosures to be included in future filings.  We refer you to Section III.B of SEC Release
34-48960.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:

 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Suying Li  at (202) 551-3335 or Nasreen  Mohammed at (202) 551-3773
if you have questions regarding comments on the fi nancial statements and related matters.

Sincerely,
   /s/Tia L. Jenkins   Tia Jenkins
Senior Assistant Chief Accountant Office of Beverages, Apparel and Mining