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SEC Comment Letter 0000000000-25-003551 to WOLVERINE WORLD WIDE INC /DE/ (WWW)

WOLVERINE WORLD WIDE INC /DE/
Date: April 3, 2025 · CIK: 0000110471 · Accession: 0000000000-25-003551

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File numbers found in text: 001-06024

Date
April 3, 2025
Author
Division of
Form
UPLOAD
Company
WOLVERINE WORLD WIDE INC /DE/

Letter

Re: Wolverine World Wide, Inc. Form 10-K for the Fiscal Year Ended December 28, 2024 Filed February 20, 2025 Form 8-K/A Furnished February 20, 2025 File No. 001-06024 Dear Taryn Miller:

April 3, 2025

Taryn Miller Chief Financial Officer Wolverine World Wide, Inc. 9341 Courtland Drive N.E. Rockford, Michigan 49351

We have limited our review of your filing to the financial statements and related disclosures and have the following comments.

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 10-K for the Fiscal Year Ended December 28, 2024 Consolidated Statements of Operations, page 36

1. We note your consolidated statements of operations include a line item for environmental and other related costs (income), net of recoveries and also note your disclosures in Note 17. Please tell us the nature of the environmental and other related costs (income), net of recoveries recorded in each of the reported periods including a description of material offsetting amounts, if any. Form 8-K/A Furnished February 20, 2025 Exhibit 99.1, page 4

2. We note your non-GAAP measures include an adjustment for reorganization costs. Please explain to us the nature of these costs and tell us why you believe they do not represent normal, recurring operating expenses. Refer to Question 100.01 of the SEC Staff s Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. April 3, 2025 Page 2

In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please contact Stephany Yang at 202-551-3167 or Kevin Woody at 202-551-3629 with any questions.

Sincerely,
Division of
Corporation Finance
Office of
Manufacturing

Show Raw Text
<DOCUMENT>
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<FILENAME>filename2.txt
<TEXT>
 April 3, 2025

Taryn Miller
Chief Financial Officer
Wolverine World Wide, Inc.
9341 Courtland Drive N.E.
Rockford, Michigan 49351

 Re: Wolverine World Wide, Inc.
 Form 10-K for the Fiscal Year Ended December 28, 2024
 Filed February 20, 2025
 Form 8-K/A Furnished February 20, 2025
 File No. 001-06024
Dear Taryn Miller:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 28, 2024
Consolidated Statements of Operations, page 36

1. We note your consolidated statements of operations include a line item
for
 environmental and other related costs (income), net of recoveries and
also note your
 disclosures in Note 17. Please tell us the nature of the environmental
and other related
 costs (income), net of recoveries recorded in each of the reported
periods including a
 description of material offsetting amounts, if any.
Form 8-K/A Furnished February 20, 2025
Exhibit 99.1, page 4

2. We note your non-GAAP measures include an adjustment for reorganization
costs.
 Please explain to us the nature of these costs and tell us why you
believe they do not
 represent normal, recurring operating expenses. Refer to Question 100.01
of the SEC
 Staff s Compliance and Disclosure Interpretations on Non-GAAP
Financial Measures.
 April 3, 2025
Page 2

 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Stephany Yang at 202-551-3167 or Kevin Woody at
202-551-3629
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>