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SEC Comment Letter for WOLVERINE WORLD WIDE (WWW) — Oct 23, 2014

WOLVERINE WORLD WIDE INC /DE/ (WWW) (CIK 0000110471)
Date: Oct. 23, 2014 · CIK: 0000110471 · Accession: 0000000000-14-052807

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File numbers found in text: 001-06024

Date
October 23, 2014
Author
/s/ Tia. L. Jenkins
Form
UPLOAD
Company
WOLVERINE WORLD WIDE INC /DE/ (WWW) (CIK 0000110471)

Letter

October 23, 2014 Via E-mail Mr. Blake W. Krueger Chief Executive Officer Wolverine World Wide , Inc. 9341 Courtland Drive, N.E. Rockford, MI 49351

Re: Wolverine World Wide, Inc. Form 10-K for the Year Ended December 28, 2013 Filed February 25 , 2014 Form 10 -Q for the Interim Period Ended June 14, 2014 Filed July 22, 2014 File No. 001-06024

Dear M r. Krueger :

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 filings, by providing the request ed information, or by advising us when you will provide the requested response. If you do not believe our comments 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 additional comments .

Form 10 -Q for the Interim Period Ended June 14, 2014

Note 15 – Subsequent Event, page 20

1. We note you r disclosures regarding the realignment of your consumer -direct operations including your plans to close approximately 140 retail stores over the next 18 months. We understand based on your comments made on your second quarter earnings call held on July 1 5, 2014, that a majority of the closures relate to your Stride Rite stores. Please address the following points:

 Identify the reporting units that are affected by the plan and quantify the balance of goodwill that you have allocated to these reporting units.

Mr. Blake W. Krueger Wolverine World Wide , Inc. October 23, 2014 Page 2

 Tell us how you considered the realignment and anticipated store closures as a possible triggering event under both FASB ASC 350 -20-35-30 and ASC 350 -30-35-18 in determining whether interim tests for impairment were necessary.

 To the extent that you have performe d an interim impairment test of your goodwill or indefinite -lived intangibles, please provide the results of your tests.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing in cludes 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 ade quacy of the disclosures they have made.

In responding to our comment s, 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 Brian McAllister at (202) 551 -3341 or Crag Arakawa , Accounting Branch Chief , at (202) 551 -3650 if you have questions regarding the financial statements and related matters . Please c ontact me with any other questions.

Sincerely,
/s/ Tia. L. Jenkins

Show Raw Text
October 23, 2014

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

Re:  Wolverine World Wide, Inc.
 Form 10-K for the Year Ended December 28, 2013
Filed February 25 , 2014
Form 10 -Q for the Interim Period  Ended June 14, 2014
Filed  July 22, 2014
File No. 001-06024

Dear M r. Krueger :

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 filings, by
providing the request ed information, or by advising us when you will provide the requested
response.   If you do not believe our comments 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 additional comments .

Form 10 -Q for the Interim Period  Ended June 14, 2014

Note 15 – Subsequent Event, page 20

1. We note you r disclosures regarding the realignment of your consumer -direct operations
including your plans to close approximately 140 retail stores over the next 18 months.
We understand based on your comments made on your second quarter earnings call held
on July 1 5, 2014, that a majority of the closures relate to your Stride Rite stores.  Please
address the following points:

 Identify the reporting units that are affected by the plan and quantify the balance of
goodwill that you have allocated to these reporting units.

Mr. Blake W. Krueger
Wolverine World Wide , Inc.
October 23, 2014
Page 2

 Tell us how you considered the realignment and anticipated store closures as a possible
triggering event under both FASB ASC 350 -20-35-30 and ASC 350 -30-35-18 in
determining whether interim tests for impairment were necessary.

 To the extent that you have performe d an interim impairment test of your goodwill or
indefinite -lived intangibles, please provide  the results of your tests.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing in cludes 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 ade quacy of the disclosures they have made.

In responding to our comment s, 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 Brian McAllister at (202) 551 -3341 or Crag Arakawa , Accounting
Branch Chief , at (202) 551 -3650  if you have questions regarding the financial statements and
related matters .  Please c ontact me with any other questions.

        Sincerely,

        /s/ Tia. L. Jenkins

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