SecProbe.io

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Mail Stop 7010

      June 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 May 6, 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 2 - Summary of Significant Accounting Policies, page F-5

Revenue Recognition Policy, page F-5
2. We have reviewed your response to comment 10.  Please confirm
that
your response regarding what constitutes normal sales terms will
be
incorporated in future filings or provide us with a supplemental
response of your proposed prospective disclosures.

Note 10 - Financing Arrangements and Debt, page F-17
3. We have reviewed your response to comment 15.  We understand
that
you may not have an obligation to affirmatively disclose that you
are
in compliance with all financial covenants.  We also noted that
you
disclosed the terms of the financial covenants in the Form 8-K
filed
on May 4, 2005.  However, you are required to disclose the terms
of
your financial covenants and waivers and amendments of the
financial
covenants in your annual and interim reports if the information is
material to an investors understanding of your financial condition
and liquidity.  Given your high financial leverage, negative cash
flows from operating activities in 2004, minimal cash flow from
operating activities in 2003, three amendments to your financial
covenants since September 2002, and your reduced financial
flexibility due to non-compliance with the financial covenants and
significant debt levels we believe that disclosure of your
compliance
with each of the terms of the financial covenants is material to
investors.

Note 21 - Industry Segments and Foreign Operations, page F-38
4. We have reviewed your response to comment 17.  In the Business
section, you disclose that the commercial products segment is
comprised of industrial tube, technical tube, copper alloy tube,
fabricated products and metal joining products.  In the Business
section you also disclosed that the wholesale segment is comprised
of
plumbing and refrigeration tube products.  Please provide the
revenues for each of these groups of products as required by
paragraphs 37 and 103 of SFAS 131.

*    *    *    *

		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.
June 1, 2005
Page 3 of 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

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