SecProbe.io

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                                (LACROSSE LOGO)

August 19, 2005

VIA EDGAR

Securities and Exchange Commission
Division of Corporation Finance
100 F Street N.E.
Washington, D.C.  20549
Attention: John Cash, Accounting Branch Chief
           Anne McConnell, Senior Staff Accountant
           Jennifer Thompson, Staff Accountant

       RE: LACROSSE FOOTWEAR, INC.
           FORM 10-K FOR FISCAL YEAR ENDED December 31, 2004
           FORMS 10-Q FOR FISCAL QUARTERS ENDED March 26, 2005 and June 25, 2005
           FILE NO. 0-238001

Ladies and Gentlemen:

LaCrosse Footwear, Inc. ("LaCrosse" the "Company") is responding via EDGAR to
the comments of the Staff of the Securities and Exchange Commission set forth in
the Staff's letter dated August 11, 2005 in connection with the Company's Form
10-K for the fiscal year ended December 31, 2004, and the Company's Forms 10-Q
for the fiscal quarters ended March 26, 2005 and June 25, 2005, respectively.

For ease of reference by the Staff in reviewing the Company's responses to each
of the comments and as requested by the Staff, each comment is referred to
separately by the number set forth in the letter from the Staff dated August 11,
2005.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004

Management's Discussion and Analysis..., page 11

Overview, page 12

COMMENT 1:  We note your statement that management of your accounts receivable
            and inventory is key. We also note that you present in tabular form
            your days sales outstanding and inventory turns for the past three
            years. However, your narrative only analyzes the change in inventory
            turns and does not analyze changes in your days sales outstanding.
            Please revise future filings to analyze changes in both of these
            metrics. Also, please consider disclosing and discussing these items
            in future quarterly filings.

            RESPONSE

            LaCrosse respectfully advises the Staff that in future filings of
            our Form 10-K we will analyze our days sales outstanding and
            inventory changes. We also advise the Staff that we will analyze
            these changes in our quarterly Form 10-Q filings.
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Fiscal 2004 Compared to Fiscal 2003, page 13

COMMENT 2:  In future filings, when you indicate that multiple factors
            contributed to a change in your results, please quantify the impact
            of each factor. In this regard, we note that your improved gross
            margin and the dollar increase in your selling and administrative
            expenses were both due to multiple factors, but it is unclear what
            the relative impact of each factor was on the total change.

            RESPONSE

            LaCrosse respectfully advises the Staff that in future Form 10-K
            filings we will individually quantify the impact of those factors
            that materially contribute to the changes in both our gross margin
            and our selling and administrative expenses.

COMMENT 3:  We note from your Schedule II that the amount charged to expense for
            your accounts receivable allowance increased significantly from 2003
            to 2004, primarily driven by a $1.1 million increase in your
            allowance for discounts. Please revise future filings to address
            this increased expense and to explain the underlying reasons for
            this increase. In this regard, you should clarify if the increase in
            discounts represents a change in your billing terms or is due to
            other factors.

            RESPONSE

            LaCrosse respectfully advises the Staff that in future Form 10-K
            filings we will explain significant increases to expense items
            included in our Schedule II. Furthermore, the disclosure will
            explain the reasons for significant changes, and whether there are
            any changes in discounts, terms, or other factors.

            LaCrosse further advises the Staff that the change in the "Charge to
            Expense" between 2003 and 2004 relates only to the accounts
            receivable general ledger accounts used to record the transaction.
            Prior to the 4th quarter of 2003 the charge was netted directly in
            accounts receivable; subsequent classification is to record in a
            contra accounts receivable account "Allowance for discounts".
            Furthermore, in both years the sales discounts properly reduced both
            accounts receivable and sales, therefore there was no underlying
            change to the actual charge to expense. All sale discounts have been
            and will continue to be classified as a reduction in sales.

Financial Statements for the Year Ended December 31, 2004
Note 6 - Stock Options, page F-16

COMMENT 4:  We note that the exercise prices of stock options cancelled in 2002
            and 2003 were significantly higher than the exercise price of stock
            options granted in those years. Please tell us if any of same people
            had both cancellations and grants in the same year, and if so, tell
            us how you determined that variable accounting was not necessary.
            Refer to Question 11(a) of FIN 44.

            RESPONSE
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            LaCrosse respectfully advises the Staff that during 2002 the Company
            announced its strategic decision to relocate its administrative and
            distribution locations resulting in a reduction in work force of 91
            employees, which resulted in stock option cancellations. Prior to
            the reduction in work force announcement those employees did have
            options granted to them at the beginning of 2002, however upon
            termination their entire unvested stock option portfolio was
            cancelled.

            LaCrosse further advises that no stock options were modified,
            directly or indirectly, to reduce the exercise price as described in
            Question 11(a) of FIN 44.

FORMS 10-Q FOR THE PERIODS ENDED MARCH 26, 2005 AND JUNE 25, 2005

Financial Statements
Note 7 - Sourcing Realignment and Facility Shutdown Charge

COMMENT 5:  We read that you have reclassified your Claremont, New Hampshire
            facility as available for sale and that you have adjusted the book
            value of this asset to its estimated net realizable value. Please
            revise future filings to quantify the amount of any loss that you
            recorded in adjusting the book value of this asset and to quantify
            the carrying value of this facility. You should also disclose which
            line item on your balance sheet contains this asset and which line
            item on your income statement contains any loss recorded in
            adjusting its carrying value. Refer to paragraph 46-47 of SFAS 144.
            If the gain or loss you record on the sale of this facility is
            significant, you should separately disclose it and also discuss it
            in MD&A.

            RESPONSE

            LaCrosse respectfully advises the Staff that in our future Form 10-Q
            filings we will revise the disclosure to identify significant
            changes to the available for sale asset. For the year ended December
            31, 2004, in Form 10-K Note 8, we disclosed the related property and
            equipment write-down of $0.4 million.

            The Company will revise future filings to include the following:

            During the 1st quarter of 2005 the Company reclassified the
            Claremont, New Hampshire facility to available for sale within the
            Other Assets section of the condensed consolidated balance sheet.
            The net realizable value of the facility, at the time of
            reclassification, was $0.6 million, which was net of a $0.4 million
            charge to selling and administrative expense during 2004. The
            Company is actively pursuing a sale of this property.

Management's Discussion and Analysis
Results of Operations

COMMENT 6:  We read that your net sales decreased from the first quarter of 2004
            primarily due to non-recurring 2004 sales. We also note that,
            excluding these non-recurring sales; your net sales increased about
            6%. If you have a similar situation in future filings, please revise
            your analysis to provide some insight into the reasons for the
            increase in your recurring sales. In this regard, it is not clear if
            this increase is due to the introduction of new, higher priced
            products, an increase in sales volume of pre-existing products, or
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            other factors. We remind you that your analysis should provide your
            readers with a view of your company's operations through
            management's eyes.

            RESPONSE

            LaCrosse respectfully advises the Staff that in future filings of
            our Form 10-Q where similar situations occur we will disclose in the
            Management's Discussion and Analysis the reasons for the underlying
            change.

In response to the Staff's specific request, the Company also acknowledges the
following:

            -  The Company is responsible for the adequacy and accuracy of the
               disclosure in the filings;

            -  Staff comments or changes to disclosure in response to Staff
               comments in the filings reviewed by the Staff do not foreclose
               the Securities and Exchange Commission from taking any action
               with respect to the filing; and

            -  The Company may not assert Staff comments as a defense in any
               proceeding initiated by the Securities and Exchange Commission or
               any person under the federal securities laws of the United
               States.

We trust you will find the foregoing responsive to the several comments of the
Staff. Please direct any questions or comments regarding this filing to the
undersigned at (503) 766-1010, ext. 1331.

                                          Sincerely,

                                          LaCROSSE FOOTWEAR, INC.

                                          /s/ David P. Carlson

                                          David P. Carlson
                                          Executive Vice President
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