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CORRESP
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CORRESP

 Deana L. McPherson, CPA

 Executive Vice
President,

 Chief Financial Officer & Treasurer

 March 10, 2023

 VIA
EDGAR

 Division of Corporation Finance

 Securities
and Exchange Commission

 100 F Street, NE

 Washington, DC
20549

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

File No. 001-31552

To Whom it May Concern,

 The following is in response to your
letter dated February 28, 2023 (the “Comment Letter”). Smith & Wesson Brands, Inc. (referred to as the “Company,” “we,” “our,” or “us”) hereby submits its responses to the comments of
the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) in the Comment Letter. Our responses are indicated below, directly following a restatement of each Staff
comment in bold, italicized type. The headings and numbers of our responses coincide with the headings and comment numbers set forth in the Comment 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.
 Where you describe two or more business reasons that contributed to a material change in a financial
statement line item between periods, please quantify, where possible, the extent to which each change contributed to the overall change in that line item. In addition, when you discuss sales fluctuations, specifically describe the extent to which
changes are attributable to changes in prices or to changes in the volume or amount of goods or services being sold or to the introduction of new products or services. As an example, we note that the 25.2% decrease in your long gun sales from fiscal
years 2021 to 2022 was caused by lower shipments of your M&P modern sporting rifles and hunting rifles partially offset by increased shipments of newly introduced products, combined with two price increases. See Item 303(b)(2) of Regulation S-K and SEC Release No. 33-8350.

  Page
 2

 Company Response: We included in our Form 10-K for the
fiscal year ended April 30, 2022 a table of unit shipments made during the fiscal year broken down by handguns and long guns, restated here as follows:

The following table sets forth certain information regarding net sales and gross profit for the fiscal years
ended April 30, 2022, 2021, and 2020 (dollars in thousands):

2022

2021

$ Change

% Change

2020

 Handguns

$
624,219

$
755,735

$
 (131,516
)

-17.4
%

$
390,711

 long Guns

189,467

253,340

(63,873
)

-25.2
%

101,540

 Other Products & Serv1ccs

50,440

50,120

320

0.6
%

37,367

 Total net sales

$
864,126

$
1,059,195

$
(195,069
)

-18.4
%

$
529,618

 Cost of sales

489,562

610,212

(120,650
)

-19.8
%

363,929

 Gross profit

$
374,564

$
448 ,983

$
(74,419
)

-16.6
%

$
165,689

 % of net sales (gross margm)

43.3
%

42.4
%

31 .3
%

 The following table sets forth certain information regarding units shipped by
trade channel for the fiscal years ended April 30, 2022, 2021, and 2020 (units in thousands):

 Total Units Shipped

2022

2021

# Change

% Change

2020

 Handguns

1,518

2,079

(561
)

-27.0
%

1,253

 Long Guns

363

524

(161
)

-30.7
%

295

 Sporting Good Channel Units Shipped

2022

2021

# Change

% Change

2020

 Handguns

1,422

1,953

(531
)

-27.2
%

1,170

 long Guns

342

508

(166
)

-32.7
%

28 1

 Professional Channel Units Shipped

2022

2021

# Change

% Change

2020

 Handguns

96

126

(30
)

-23.8
%

83

 Long Guns

21

16

5

31.3
%

14

 The information included in this table indicates that long gun units in the sporting goods channel declined by
32.7% compared to the prior fiscal year, and related commentary indicates that long gun sales declined by 25.2% compared to the prior fiscal year due primarily to a decrease in shipped units. As the unit decline was greater than the dollar decline,
we indicated that there were new products introduced during the fiscal year and that we had implemented two price increases. We are unable to specify exactly how much the dollar value of long guns was impacted by price changes because our mix of
product changed during the period, as explained in our commentary regarding the discontinuation of sales of hunting rifles and the introduction of new products, which we noted accounted for 19.8% of total net sales. Given the number of different
products we offer, combined with the introduction of new products and the change in mix of our products, we do not believe that additional specific commentary on the change in sales is possible.

  Page
 3

 Critical Accounting Policies, page 44

2.
 In future filings, please enhance your disclosure to provide qualitative and quantitative information
necessary to understand the estimation uncertainty and the impact your critical accounting estimates have had or are reasonably likely to have on your financial condition and results of operations. In addition, discuss how much each estimate and/or
assumption has changed over a relevant period and the sensitivity of reported amounts to the underlying methods, assumptions and estimates used. The disclosures should supplement, not duplicate, the description of accounting policies or other
disclosures in the notes to the financial statements. Refer to Item 303(b)(3) of Regulation S-K and SEC Release No. 33-8350.

Company Response: We will enhance our disclosure in future Form 10-K filings to provide qualitative and
quantitative information to assist with understanding the uncertainty and impact that our critical accounting estimates have or are reasonably likely to have on our financial condition and results of operations. We will also disclose changes in
estimates and/or assumptions and the sensitivity of reported amounts to the underlying methods, assumptions, and estimates used over the relevant period, if any.

Form 10-Q for the quarterly period ended October 31, 2022

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Results of Operations, page 19

3.
 We note your disclosures on pages 20 and 21 that the decline in your gross margins for the three and six-months ended October 31, 2022 was due in part to inflation in both material costs and labor. In future filings, please expand your disclosures to identify the principal factors contributing to your
inflationary pressures and the actions planned or taken, if any, to mitigate the inflationary pressures and to quantify the resulting impact on your results of operations and financial condition.

Company Response: In our Form 10-Q filing for the quarterly period ended October 31, 2022, we note
that inflation in material and labor negatively impacted our gross margin. In future filings, we will note broad material categories, such as raw materials and finished parts, and attempt to provide the impact that inflation has had on these
categories in total. Similarly, in future filings, we will note which general categories of labor in which we are experiencing the most significant inflationary pressure. We will also provide additional disclosure regarding our ability, or lack
thereof, to mitigate inflationary impacts.

 We hope that this resolves the questions as outlined in the Comment Letter. Should you have any further
questions, please do not hesitate to contact me.

 Sincerely,

/s/ Deana L. McPherson

Deana L. McPherson, CPA

Executive Vice President, Chief Financial Officer, and Treasurer