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SEC Company Response from SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796) (SWBI) — Jun 25, 2007

SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796)
Date: June 25, 2007 · CIK: 0001092796 · Accession: 0000950153-07-001374

Offering / Registration Process Regulatory Compliance Financial Reporting

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File numbers found in text: 333-141231

Date
June 25, 2007
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

June 25, 2007

Via Facsimile (202-772-9368) and EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Attention: Matt Franker

Re:

Smith & Wesson Holding Corporation

Form S-3

File No. 333-141231

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 5:00 p.m., Eastern time, on June 26, 2007, 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.

As soon as the Commission has declared the Registration Statement effective, please call Robert S. Kant at Greenberg Traurig, LLP at (602) 445-8302, and then send written confirmation to the addresses listed on the cover of the Registration Statement.

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

June 25, 2007

Via Facsimile (202-772-9368) and EDGAR

Securities
and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Attention: Matt Franker

              Re:

    Smith & Wesson Holding Corporation

Form S-3

File No. 333-141231

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 5:00 p.m., Eastern
time, on June 26, 2007, 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.

          As soon as the Commission has declared the Registration Statement effective, please call
Robert S. Kant at Greenberg Traurig, LLP at (602) 445-8302, and then send written confirmation to
the addresses listed on the cover of the Registration Statement.

    Very truly yours,

SMITH & WESSON HOLDING CORPORATION

    By:
    /s/ John A. Kelly

    Name:
    John A. Kelly

    Title:
    Chief Financial Officer

cc:      Robert S. Kant