SecProbe.io

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

                                 August 26, 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
August 9th. For your convenience, we have repeated the text of your comments,
followed by our response.

         We respectfully respond to your comments as follows:

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

     1.  BASED ON THE INFORMATION YOU PROVIDED IT APPEARS THAT THE FOLLOWING
         WHOLESALE OPERATING SEGMENTS ARE QUANTITATIVELY SIGNIFICANT AT THE TEN
         PERCENT LEVEL: ROCKY - MANUFACTURED, ROCKY - SOURCED, AND WHOLESALE
         ACCESSORIES COMBINED. BASED ON THE INFORMATION YOU PROVIDED IT APPEARS
         THAT THESE OPERATING SEGMENTS ARE ECONOMICALLY DISSIMILAR AND SHOULD
         NOT BE AGGREGATED. PLEASE REVISE YOUR PREVIOUS STATEMENT ACCORDINGLY.
         FINALLY, WE AGREE WITH YOUR CONCLUSION THAT YOU HAVE SEPARATE MILITARY
         AND RETAIL REPORTABLE SEGMENTS.

         RESPONSE:

We acknowledge the Staff's comment, and confirm the information discussed in our
August 19, 2005 phone conversation with the Staff. As you requested, Exhibit A
(attached) is a copy of our internal financial report for the second quarter of
2005, which includes net sales by product groups and profitability for each
operating segment. You will note that the information by product group relates
only to sales and not profit measure.

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Letter to Michael Moran
August 26, 2005
Page -2-

On January 6, 2005, the Company purchased EJ Footwear Group in an acquisition
that has doubled the size of the business. Because of the acquisition, the
Company has redesigned the internal financial reporting information that is
provided to the chief operating decision maker (CODM) and to the Board of
Directors. This revision was effective with the Company's first quarter of 2005.

The redesigned internal financial reporting provides net sales and gross margin
information for three operating segments: Wholesale, Retail and Military. This
is now the only information used to assess operating performance provided to the
CODM and to the Board of Directors. As such, the Company believes that these are
its operating segments as defined in Financial Accounting Standard No. 131,
"Disclosures about Segments of an Enterprise and Related Information" (FAS 131),
paragraph 10:

         An operating segment is a component of an enterprise:

         a. That engages in business activities from which it may earn revenues
         and incur expenses (including revenues and expenses relating to
         transactions with other components of the same enterprise),

         b. Whose operating results are regularly reviewed by the enterprise's
         chief operating decision maker to make decisions about resources to be
         allocated to the segment and assess its performance, and

         c. For which discrete financial information is available.

The Company believes that these operating segments cannot be aggregated under
FAS 131, paragraph 17, because the segments have different economic
characteristics. Profitability information is no longer provided to the CODM for
the Company's previous eight operating segments.

No information below gross margin is prepared; that is, selling, general and
administrative information is not allocated by segment. Only consolidated
balance sheet information is prepared, therefore asset information by segment is
not prepared.

In previous filings, the Company has disclosed net sales of its product groups
in the footnotes to the financial statements, and in management's discussion and
analysis of financial condition and results of operations. In future filings,
the Company will continue to disclose information related to net sales of
product groups.

Because the Company has already changed its internal financial reporting because
of the acquisition in January 2005, and has been reporting to CODM and Board of
Directors on the revised basis since the first quarter of 2005, the Company
believes it is more appropriate to report using the three operating (and
reporting) segments: Wholesale, Retail and Military. Our Form 10-Q for the
quarter ended June 30, 2005 was prepared consistent with our new internal
reporting. In future filings, the Company will report three segments: Wholesale,
Retail and Military.

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, Retail and Military.

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Letter to Michael Moran
August 26, 2005
Page -3-

                                    * * * * *

         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

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Letter to Michael Moran
August 26, 2005
Page -4-

                                                                  Exhibit A

                       2ND QUARTER 2005 FINANCIAL REVIEW*

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

*    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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