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SEC Company Response from SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796) (SWBI) — Sep 4, 2009

SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796)
Date: Sept. 4, 2009 · CIK: 0001092796 · Accession: 0000950123-09-041113

Offering / Registration Process Regulatory Compliance Financial Reporting

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File numbers found in text: 333-160911

Date
September 4, 2009
Author
SMITH & WESSON HOLDING CORPORATION
Form
CORRESP
Company
SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796)

Letter

SMITH & WESSON HOLDING CORPORATION

2100 Roosevelt Avenue

Springfield, Massachusetts 01104

September 4, 2009

VIA FACSIMILE (703-813-6968) AND EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Sherry Haywood

Re:

Smith & Wesson Holding Corporation

Form S-3

File No. 333-160911

Ladies and Gentlemen:

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Smith & Wesson Holding Corporation (the “Company”) hereby requests that the effective date of the above-captioned Registration Statement be accelerated to 10:00 a.m., Eastern time, on Wednesday, September 9, 2009, or as soon as practicable thereafter.

The Company acknowledges that (1) should the Commission or staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement, (2) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement, and (3) the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
SMITH & WESSON HOLDING CORPORATION

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CORRESP
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corresp

SMITH & WESSON HOLDING CORPORATION

2100 Roosevelt Avenue

Springfield, Massachusetts 01104

September 4, 2009

VIA FACSIMILE (703-813-6968) AND EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Sherry Haywood

              Re:

    Smith & Wesson Holding Corporation

Form S-3

File No. 333-160911

Ladies and Gentlemen:

          In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of
1933, as amended, Smith & Wesson Holding Corporation (the “Company”) hereby requests that the
effective date of the above-captioned Registration Statement be accelerated to 10:00 a.m., Eastern
time, on Wednesday, September 9, 2009, or as soon as practicable thereafter.

          The Company acknowledges that (1) should the Commission or staff, acting pursuant to delegated
authority, declare the Registration Statement effective, it does not foreclose the Commission from
taking any action with respect to the Registration Statement, (2) the action of the Commission or
the staff, acting pursuant to delegated authority, in declaring the Registration Statement
effective, does not relieve the Company from its full responsibility for the adequacy and accuracy
of the disclosure in the Registration Statement, and (3) the Company may not assert staff comments
and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or
any person under the federal securities laws of the United States.

    Very truly yours,

    SMITH & WESSON HOLDING CORPORATION

    By:

Name:

    /s/ Michael F. Golden

Michael F. Golden

    Title:

    President and Chief Executive Officer