SecProbe.io

CORRESP
1
filename1.htm

CORRESP

 Jeffrey D. Buchanan

Executive Vice President,

Chief Financial Officer & Treasurer

 February 7, 2013

 VIA EDGAR

Rufus Decker, Accounting Branch Chief

Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, NE

Washington, D.C. 20549

RE:
Smith & Wesson Holding Corporation

Form 10-K for Fiscal Year Ended April 30, 2012

Filed June 28, 2012

Response dated January 29, 2013

File No. 1-31552

 Dear
Mr. Decker:

 The following is in response to your letter dated January 31, 2013 (the “Comment Letter”).
Smith & Wesson Holding Corporation (referred to as the “Company,” “we,” “our,” or “us”) hereby submits its response to the comment of the staff (the “Staff”) of the Division of Corporation
Finance of the Securities and Exchange Commission (the “Commission”) in the Comment Letter. Our response is indicated below, directly following a restatement of the Staff comment in bold, italicized type. The heading and number of our
response coincides with the heading and comment number set forth in the Comment Letter.

 Item 15 – Exhibits and Financial
Statement Schedules, page 39

 Consolidated Financial Statements, page F-1

 Note 2 – Significant Accounting Policies, page F-8

 General

1.
Comment: We have reviewed your response to prior comment six from our letter dated January 15, 2013. Please also disclose in future filings the types
of expenses that you include in the general and administrative expenses line item. Please show us supplementally what your revised disclosure will look like.

 Rufus Decker

 Page 2

 Company Response: We include payroll and benefits for management and
administrative employees; profit sharing and stock compensation expenses; information technology costs; legal and professional fees; depreciation of furniture, fixtures, and computer equipment; reserves for bad debts; and expenses for administrative
functions in the general and administrative expenses line item. In our future filings, we will disclose the types of expenses that we include in the general and administrative expenses line item.

Pursuant to your request, we propose to add the following to footnote 2 to the consolidated financial statements:

“General and Administrative Expenses — In the accompanying consolidated financial statements, we included payroll and
benefits for management and administrative employees; profit sharing and stock compensation expenses; information technology costs; legal and professional fees; depreciation of furniture, fixtures, and computer equipment; reserves for bad debts; and
expenses for administrative functions in general and administrative operating expenses.”

 * * * *

In connection with this response, we acknowledge that we are responsible for the adequacy and accuracy of the disclosure in our filings.
Furthermore, we acknowledge that staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing. Finally, we acknowledge that we do 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 hope that this resolves the questions as outlined in your memo. Should you have any further questions, please do not hesitate to
contact me.

 Sincerely,

 /s/
Jeffrey D. Buchanan

 Jeffrey D. Buchanan

 Executive Vice President, Chief Financial Officer,

 and Treasurer