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                            ROCKY SHOES & BOOTS, INC.
                              39 EAST CANAL STREET
                             NELSONVILLE, OHIO 45764

                                 August 4, 2005

VIA EDGAR AND OVERNIGHT COURIER
-------------------------------

Michael Moran, Esq.
Branch Chief
Division of Corporation Finance
United States Securities and Exchange Commission
Mail Stop 3-8
100 F. Street, N.E.
Washington, D.C. 20549

         Re:      Rocky Shoes & Boots, Inc.
                  File No. 0-21026
                  Form 10-K for the fiscal year ended December 31, 2004
                  Form 10-Q for the fiscal year ended March 31, 2005

Dear Mr. Moran:

         We have received your additional comments to the annual report on Form
10-K for the fiscal year ended December 31, 2004, filed by Rocky Shoes & Boots,
Inc. (the "Company"), as set forth in your letter to the Company dated as of
July 22, 2005. For your convenience, we have repeated the text of your comment,
followed by our response.

         We respectfully respond to your comment as follows:

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

     1.  WE NOTE YOUR RESPONSE TO COMMENT TWO OF OUR LETTER DATED JUNE 15, 2005.
         PLEASE PROVIDE TO US THREE YEARS OF REVENUE INFORMATION FOR EACH
         OPERATING SEGMENT YOU HAVE IDENTIFIED. ALSO, PROVIDE THREE YEARS OF
         PROFIT (LOSS), AND ASSET INFORMATION FOR EACH OPERATING SEGMENT
         IDENTIFIED. SEE PARAGRAPH 18 OF SFAS NO. 131.

         RESPONSE:

         The Company has attached Schedule A, which is an analysis of sales and
         gross margin for each of the three years in the period ended December
         31, 2004 for each operating segment, and the average gross margin for
         such three year period.

         Information regarding segment assets has not been provided because such
         information is not prepared by the Company, and is not used by the
         chief operating decision maker to assess segment performance. Financial
         Accounting Standards Board Staff Implementation Guide

<PAGE>

Letter to Michael Moran
August 4, 2005
Page -2-

         "Segment Information: Guidance on Applying Statement 131", Question #4
         states, "...allocation of assets is not a criterion for the component
         to be considered an operating segment. If no asset information is
         provided for a reportable segment, that fact and the reason therefor
         should be disclosed." In future filings, the Company will disclose that
         asset information by segment is not prepared because such information
         is not used to assess segment performance.

         As discussed in our letter to the Staff dated July 15, 2005, the
         Company has determined that it has three reportable segments,
         Wholesale, Military and Retail. Also as discussed in that letter,
         Military and Retail are separate operating segments that cannot be
         aggregated, and are therefore reportable segments. However, the Company
         believes that each of the operating segments in the Wholesale
         reportable segment have similar economic characteristics that allow for
         aggregation of the operating segments into a single reportable segment.
         The following discussion will only focus on the Wholesale operating
         segments, as shown in Schedule A.

         In concluding that the economic characteristics of the Wholesale
         operating segments are similar, the Company has considered the guidance
         contained in Financial Accounting Standards Board Statement No. 131
         "Disclosures about Segments of an Enterprise and Related Information"
         (FAS 131) and Financial Accounting Standards Board Staff Implementation
         Guide "Segment Information: Guidance on Applying Statement 131"
         (Implementation Guide). Paragraph 17 of FAS 131 states "Operating
         segments often exhibit similar long-term financial performance if they
         have similar economic characteristics.... Two or more operating
         segments may be aggregated into a single operating segment if
         aggregation is consistent with the objective and basic principles of
         this Statement, if the segments have similar economic characteristics,
         ..." Implementation Guide Question #8 states, "operating segments are
         considered to be similar if they can be expected to have essentially
         the same future prospects. Therefore, the similarity of the economic
         characteristics should be evaluated based on future prospects and not
         necessarily on the current indicators only. In other words, if the
         segments do not currently have similar gross margins and sales trends
         but the economic characteristics and the other five criteria are met
         and the segments are expected to again have similar long-term average
         gross margins and sales trends, the two segments may be aggregated."

         Net Sales

         As Schedule A reflects, the Company has generally experienced an
         increase in sales in all Wholesale operating segments during the
         period, except for Rocky manufactured and Wildwolf.

         When assessing the expected performance of the Rocky manufactured
         operating segment, sales of the Rocky manufactured operating segment
         must consider the effect of military sales because all military sales
         are manufactured. Total sales of manufactured products were $* (Rocky
         manufactured plus military, as shown in Schedule A) in 2004 as compared
         to $* in 2003 and $* in 2002, an increase of *% from 2004 as compared
         to 2002. Note that (1) retail sales also include manufactured products
         (the amount of which is not available), and (2) the sales increase in
         2004 is affected by the lower sales price on military sales. The
         Company makes its decisions regarding manufacturing versus sourcing
         products based on consideration of the lowest cost to obtain the
         product, at the quality level expected by the customer.

         ----------------

         *        This information has been redacted pursuant to a
                  confidentiality treatment request filed with the Securities
                  and Exchange Commission on the same date as this letter.

<PAGE>

Letter to Michael Moran
August 4, 2005
Page -3-

         The decline in Rocky manufactured sales in 2004 results from the need
         to use production facilities to manufacture footwear for the U.S.
         Military. Without this contract, the Company believes that sales of
         manufactured footwear would have been greater had the production
         facilities not been used for manufacturing military footwear. Rocky
         manufactured operating segment sales had a decline in 2003 because the
         mix of products ordered by customers resulted in the decision to source
         more product based on the cost and quality considerations discussed
         above. As the Company has received a military contract in 2005 and
         expects to bid for military contracts in the future, the Company
         expects to have future increases in sales of total manufactured
         products (Rocky manufactured plus military).

         Wildwolf is a brand primarily sold to Wal-Mart. Sales in 2004 were
         slightly lower than the prior year. However, the Company expects sales
         of this brand to have the same future trend as that of its other
         wholesale products. The Company notes that the Wildwolf operating
         segment is not quantitatively significant.

         Sales of Rocky apparel and of other accessories have increased more
         than sales of the footwear operating segments. The primary reason for
         this increase is that, in 2002, the Company introduced its Rocky
         apparel product line. Because the Company has enjoyed success in
         initial introduction of these product lines, the products have
         experienced a greater percentage increase than footwear operating
         segments. Also, the Company acquired the Gates glove brand and certain
         related inventory in 2003, which cause the significant sales increase
         as compared to 2002. The percentage sales increases of these operating
         segments for the period 2002 to 2004 are greater than those that will
         be experienced in the future, because the segments were "start-ups"
         during the past three years. In the long-term, as these operating
         segments mature, the Company expects sales growth of these operating
         segments to approximate those of the other Wholesale operating
         segments. As such, in accordance with Implementation Guide Question #8,
         these operating segments are aggregated because they are expected to
         have similar economic characteristics in the future.

         Gross Margin

         The Company does not prepare segment profitability information below
         the gross margin level. Internally, the Company uses gross margin to
         evaluate segment profitability.

         As detailed in Schedule A, the three-year average gross margin
         percentage of the Wholesale operating segments of the Company has
         averaged in a range of *% to *%, and the gross margin range is *% to *%
         in 2004. In addition, as can be seen in Schedule A, the gross margin
         percentages of the Wholesale operating segments have generally trended
         up. The profit margin differences of the Wholesale operating segments
         have been reduced as the product lines introduced in the last three
         years have reached volume levels that allow for a more typical gross
         margin levels. Because all Wholesale operating segments sell apparel
         type products to the same base of retail customers, the Company expects
         the long-term profit margins to become even more comparable in the
         future, as can be seen in the gross margin trends in Schedule A.

         ----------------

         *        This information has been redacted pursuant to a
                  confidentiality treatment request filed with the Securities
                  and Exchange Commission on the same date as this letter.

<PAGE>

Letter to Michael Moran
August 4, 2005
Page -4-

         Schedule A also shows that the Rocky manufactured operating segment
         experiences a slightly lower gross margin than the other Wholesale
         operating segments. The Company must maintain manufacturing facilities
         in order to be able to meet its wholesale customers' demand for "made
         in the U.S." products, and to service customer rush orders that cannot
         be shipped from the Far East. These products generally have a slightly
         lower profit margin than other wholesale products, but generally have a
         gross margin trend that is similar to the other Wholesale operating
         segments. The Company makes its decision to manufacture versus source
         products based on the cost and quality considerations described above.
         As it expands its customer base, including further expansion from the
         EJ Footwear acquisition, the Company expects that gross margin of
         manufactured products will approximate the margin experienced on the
         other Wholesale operating segments.

         The other accessories operating segments gross margin has declined to
         be more comparable with the remaining operating segments.

         Summary - The Company has considered the guidance contained in FAS 131
         and the Implementation Guide (see above) and believes that the
         Wholesale operating segments, as detailed in Schedule A, currently
         have, and are expected to have similar economic characteristics.
         Therefore, it is appropriate to aggregate these six operating segments
         into one reporting segment, referred to as Wholesale.

         The Company is amending its Form 10-Q for the quarter ended March 31,
         2005 for pro forma information related to the EJ Footwear acquisition,
         as required by the Staff in comment #26 of the letter dated May 13,
         2005. The Company will also amend the footnotes to the condensed
         consolidated financial statements and management's discussion and
         analysis of financial condition and results of operations in such Form
         10-Q to include segment disclosure for three reportable segments -
         Wholesale, Military and Retail. In addition, future filings will also
         contain such presentation of segment information.

                                    * * * * *

<PAGE>

Letter to Michael Moran
August 4, 2005
Page -5-

         If you have any questions regarding any of the foregoing, please
contact Robert J. Tannous, Porter, Wright, Morris & Arthur LLP at (614)
227-1953.

         Thank you for your assistance.

                                             Very truly yours,

                                             /s/ James E. McDonald

                                             James E. McDonald,
                                             Executive Vice President and
                                             Chief Financial Officer

cc:   Robert Babula (SEC - Staff Accountant)
      Christopher Owings (SEC - Assistant Director)
      Robert J. Tannous

<PAGE>
Letter to Michael Moran
August 4, 2005
Page -6-

                               ROCKY SHOES & BOOTS
                        STATEMENT OF SALES & GROSS MARGIN

                                                                   SCHEDULE A

                                       *

----------------

* This information has been redacted pursuant to a confidentiality
  treatment request filed with the Securities and Exchange Commission on
  the same date as this letter.

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