SecProbe.io

November 18 , 2013

Via E -Mail
Mr. Blake W. Krueger
Chief Executive Officer
Wolverine World Wide, Inc.
9341 Courtland Drive N.E.
Rockford, M I 49351

Re: Wolverine World Wide, I nc.
 Form 10-K for the Year Ended December 29, 2012
Filed February 2 7, 2013
File No. 001-06024

Dear Mr. Krueger :

We have reviewed your filing an d 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 advising us when you will provide the requested
response.   If you do not believe our comme nts apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additio nal comments.

Form 10 -K for the Year Ended December 29, 2012

Financial Statements

Consolidated Balance Sheets , page A -1

1. Please present goodwill separately from indefinite -lived intangibles  on your balance sheet
in future filings .  Refer  to ASC 350 -20-45-1 and ASC 350 -30-45-1.

2. In future filings, please  separately disclose, either on your  balance sheet or in your
footnotes, any elements of other accrued liabilities that exceed  5 percent  of total current
liabilities.  Refer to  Rule 5 -02(20) of Regulation S -X.  Please show us supplementally
your revised disclosures, if applicable.

Mr. Blake W. Krueger
Wolverine World Wide  Inc.
November 18 , 2013
Page 2

Form 10 -Q for the Period Ended September 7, 2013

General

3. Please address the comments above in your interim filings, as applicable.

Financial Statements

Note 15. Subsidiary Guarantors of the Notes, page 19

4. Please disclose, if true,  that each of your guarantor subsidiaries are 100% owned as
defined in Rule 3 -10(h) of Regulation S -X.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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 provide  a written statement from the company
acknowledging that:

 the company is responsible for the  adequacy and accuracy of the disclosure 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 federal securities laws of the United States.

You may contact Dee Dee Hurst  at 202-551-3681  or Rufus Decker  at 202-551-3769  if
you have questions regarding comments on the  financial statements and re lated matters.

Sincerely,

/s/Tia L. Jenkins

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