SEC Comment Letter 0000000000-23-002519 to SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796) (SWBI)
SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796)
Date: March 15, 2023 · CIK: 0001092796 · Accession: 0000000000-23-002519
AI Filing Summary & Sentiment
File numbers found in text: 001-31552
Letter
United States securities and exchange commission logo March 15, 2023 Deana McPherson Executive Vice President and Chief Financial Officer Smith & Wesson Brands, Inc. 2100 Roosevelt Avenue Springfield, MA 01104 Re:Smith & Wesson Brands, Inc. Form 10-K for the Fiscal Year Ended April 30, 2022 Form 10-Q for the quarterly period ended October 31, 2022 Response dated March 10, 2023 File No. 001-31552 Dear Deana McPherson: We have reviewed your March 10, 2023 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our February, 28, 2023 letter. Form 10-K for the Fiscal Year Ended April 30, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 38 1.We note your response to comment 1 and have the following comments:
•Please confirm that when you describe two or more business reasons that contributed to a material change in any financial statement line item between periods, you will quantify, where possible, the extent to which each change contributed to the overall change in that line item.
•In regards to your sales fluctuations, explain to us in greater detail why you are not
FirstName LastNameDeana McPherson Comapany NameSmith & Wesson Brands, Inc. March 15, 2023 Page 2 FirstName LastName Deana McPherson Smith & Wesson Brands, Inc. March 15, 2023 Page 2 able to quantify changes attributable to prices and volumes. In doing so, clarify if certain price and/or volume information is not available or not provided at a certain level of specificity. If you conclude such information is not calculable, quantify the price and volume information that is determinable, such as material product line discontinuations, and better describe the relative significance of the factors impacting sales fluctuations. You may contact Charles Eastman at 202-551-3794 or Andrew Blume at 202-551-3254 if you have any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
March 15, 2023
Deana McPherson
Executive Vice President and Chief Financial Officer
Smith & Wesson Brands, Inc.
2100 Roosevelt Avenue
Springfield, MA 01104
Re:Smith & Wesson Brands, Inc.
Form 10-K for the Fiscal Year Ended April 30, 2022
Form 10-Q for the quarterly period ended October 31, 2022
Response dated March 10, 2023
File No. 001-31552
Dear Deana McPherson:
We have reviewed your March 10, 2023 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
February, 28, 2023 letter.
Form 10-K for the Fiscal Year Ended April 30, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 38
1.We note your response to comment 1 and have the following comments:
•Please confirm that when you describe two or more business reasons that contributed
to a material change in any financial statement line item between periods, you will
quantify, where possible, the extent to which each change contributed to the overall
change in that line item.
•In regards to your sales fluctuations, explain to us in greater detail why you are not
FirstName LastNameDeana McPherson
Comapany NameSmith & Wesson Brands, Inc.
March 15, 2023 Page 2
FirstName LastName
Deana McPherson
Smith & Wesson Brands, Inc.
March 15, 2023
Page 2
able to quantify changes attributable to prices and volumes. In doing so, clarify if
certain price and/or volume information is not available or not provided at a certain
level of specificity. If you conclude such information is not calculable, quantify the
price and volume information that is determinable, such as material product line
discontinuations, and better describe the relative significance of the factors impacting
sales fluctuations.
You may contact Charles Eastman at 202-551-3794 or Andrew Blume at 202-551-3254 if
you have any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing