SecProbe.io

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Mail Stop 7010

      July 1, 2005

Mr. Thomas B. Sabol
Executive Vice President Chief Financial Officer
Wolverine Tube, Inc.
200 Clinton Avenue West, Suite 1000
Huntsville, Alabama 35801

	Re: 	Form 10-K for Fiscal Year Ended December 31, 2004
                   	Form 10-Q for Fiscal Quarter Ended March 31,
2005
	       	File No. 1-12164

Dear Mr. Sabol:

		We have reviewed your response letter dated June 15,
2005
and have the following additional comments.  If you disagree with
a
comment, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the Year Ended December 31, 2004

General
1. Where a comment below requests additional disclosures or other
revisions, please show us in your supplemental response what the
revisions will look like.  These revisions should be included in
your
future filings, including your interim filings where applicable.

Note 21 - Industry Segments and Foreign Operations, page F-38
2. We have reviewed your response to comment 4.  We understand
that
the products in your segments have similar customers, are
distributed
through the same distribution channels and also have similar terms
and conditions of sales.  Accordingly, we believe that you may
have
substantially complied with the aggregation criteria specified by
paragraph 17 of SFAS 131 for the purpose of determining reportable
segments.  However, our comment specifically addressed the
enterprise-wide disclosures for revenues of each product or group
of
products required by paragraphs 37 of SFAS 131.  This requirement
is
supplemented by paragraph 103 of SFAS 131 which describes the
reasons
why enterprise-wide disclosures are appropriate for all
enterprises.
Based on our review of the description of your business in Item 1
of
your Form 10-K report as well as the Our Products section of your
website it is apparent that you sell various similar products
within
the industrial tube, technical tube, copper alloy tube, fabricated
products and metal joining products categories within your
commercial
products segment.  In fact, you offer over 2,000 product
variations
alone in the metal joining product category.  Likewise, you sell
various similar products within the plumbing and refrigeration
tube
products categories within your wholesale products segment.
Paragraphs 37 and 103 of SFAS 131 require that you disclose
revenue
amounts for each of the major product categories within your
reportable business segments.  Item 101(c)(i) of Regulation S-K
also
requires that you disclose the amount of total revenue contributed
by
class of similar products which account for 10% or more of
consolidated revenue.  If the disclosure requirement was to simply
state the amount of segment revenues, there would be no necessity
for
the enterprise-wide provisions of SFAS 131.  We urge you to
provide
revenue by major product categories as required by SFAS 131 and
Regulation S-K.

*    *    *    *

		Please respond to these comments within 10 business
days,
or tell us when you will provide us with a response.  Please
provide
us with a supplemental response letter that keys your responses to
our comments and provides any requested supplemental information.
Detailed letters greatly facilitate our review.  Please file your
supplemental response on EDGAR as a correspondence file.  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 Gus Rodriguez, Staff Accountant, at (202) 551-3752
or,
in his absence, Nate Cheney, Assistant Chief Accountant, at (202)
551-3714.

          						Sincerely,

								Rufus Decker
								Branch Chief

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Thomas B. Sabol
Wolverine Tube, Inc.
July 1, 2005
Page 3 of 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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