SEC Comment Letter for SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796) (SWBI) — Apr 12, 2016

SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796)
Date: April 12, 2016 · CIK: 0001092796 · Accession: 0000000000-16-071864

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AI Filing Summary & Sentiment

Sentiment

Urgency

Document Type

Confidence

SEC Posture

Company Posture

Summary

Reasoning

Date

April 12, 2016

Author

/s/ Terence O ’Brien

Form

UPLOAD

Company

SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796)

Letter

Mail Stop 4631 April 12 , 2016 Via E -mail Mr. Jeffrey D. Buchanan Chief Financial Officer Smith & Wesson Holding Corporation 2100 Roosevelt Avenue Springfield, Massachusetts 01104

RE: Smith & Wesson Holding Corporation Form 10 -K for the Year E nded April 30 , 2015 Filed June 22 , 2015 File No. 1 -31552

Dear Mr. Buchanan :

We have completed our review of your filings. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing s and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Terence O ’Brien

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Mail Stop 4631

April 12 , 2016

Via E -mail
Mr. Jeffrey D. Buchanan
Chief Financial Officer
Smith & Wesson Holding Corporation
2100 Roosevelt Avenue
Springfield, Massachusetts  01104

RE: Smith & Wesson Holding Corporation
Form 10 -K for the Year E nded April 30 , 2015
Filed June 22 , 2015
File No. 1 -31552

Dear Mr. Buchanan :

We have completed our review of your filings.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing s and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the
information the Securities Exchange Act of 1934 and all applicable rules require.

       Sincerely,

       /s/ Terence O ’Brien

Terence O’Brien
       Accounting Branch Chief
Office of Manufacturing and Construction

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