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SEC Company Response from SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796) (SWBI) — Jan 9, 2006

SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796)
Date: Jan. 9, 2006 · CIK: 0001092796 · Accession: 0000950153-06-000038

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File numbers found in text: 333-130634

Date
January 10, 2006
Author
/s/Robert S. Kant
Form
CORRESP
Company
SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796)

Letter

January 9,

VIA EDGAR AND FACSIMILE (202) 772-9369

Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 7010

100 F Street, N.E.

Washington, D.C. 20549

Attention: Lesli Sheppard

Re:

Smith & Wesson Holding Corporation

Registration Statement on Form S-3

File No. 333-130634

Ladies and Gentlemen:

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, on behalf of Smith & Wesson Holding Corporation (the "Company") we hereby request that the effective date of the above-referenced Registration Statement be accelerated to 2:00 p.m., Eastern Standard Time, on Tuesday, January 10, 2006 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 filing, (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 filing, and (3) the Company may not assert such action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely,
/s/Robert S. Kant

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CORRESP
1
filename1.htm

corresp

January 9,
2006

VIA EDGAR AND FACSIMILE (202) 772-9369

Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 7010

100 F Street, N.E.

Washington, D.C. 20549

Attention: Lesli Sheppard

         Re:

    Smith & Wesson Holding Corporation

Registration Statement on Form S-3

File No. 333-130634

Ladies and Gentlemen:

     In accordance
with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended,
on behalf of Smith & Wesson Holding Corporation (the "Company") we hereby request that the effective
date of the above-referenced Registration Statement be accelerated to 2:00 p.m., Eastern Standard
Time, on Tuesday, January 10, 2006 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 filing, (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 filing, and (3) the Company may not assert such action as a defense
in any proceeding initiated by the Commission or any person under the federal securities
laws of the United States.

    Sincerely,

    /s/Robert S. Kant

    cc:

    Michael F. Golden
President and CEO