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United States securities and exchange commission logo
May 31, 2022
Michael Stornant
Chief Financial Officer
Wolverine World Wide, Inc.
9341 Courtland Drive N.E.
Rockford, MI 49351
Re: Wolverine World
Wide, Inc.
Form 10-K for the
Fiscal Year Ended January 1, 2022
Form 10-Q for the
Quarter Ended April 2, 2022
File No. 001-06024
Dear Mr. Stornant:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended January 1, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
2021 Financial Overview, page 25
1. We note the disclosure
of your growth in eCommerce and direct-to-consumer revenue
from period to period
on a percentage basis. We also note these growth percentages in
your earnings release
presentations as well as related investor presentations. Please tell us
your consideration of
disclosing the dollar amounts of related revenue for each of these
revenue streams in your
earnings presentations and annual and periodic filings as it
appears such
information would be meaningful to investors. Refer to Item 303 of
Regulation S-K.
Additionally, please clarify the nature of any differences between
revenue categorized as
"direct-to-consumer revenue," "consumer-direct revenue" and
"eCommerce revenue" as
all three of these labels appear in your filings.
Michael Stornant
FirstName LastNameMichael
Wolverine World Wide, Inc. Stornant
Comapany
May NameWolverine World Wide, Inc.
31, 2022
May 31,
Page 2 2022 Page 2
FirstName LastName
Notes to Consolidated Financial Statements
6. Revenue from Contracts with Customers, page 50
2. We note you disaggregate revenue by segment and by wholesale vs.
consumer direct
channels. Please tell us what consideration you gave to further
disaggregation by brand
and further disclosure for your e-Commerce channels. For example, in
certain of your
investor presentations and earnings releases, you present revenue by
brand in percentages,
and in dollars for the first fiscal quarter ended April 2, 2022,
whereas only percentage
change was provided previously. You also present revenue growth
percentages for DTC
revenue and for eCommerce and Stores for each of your brands where
applicable. Refer
to the guidance in ASC 606-10-50-5 and related implementation guidance
in ASC 606-10-
55-90 and 91.
18. Business Segments, page 66
3. We note your disclosure in Note 18 that your portfolio of brands is
organized into two
operating segments which you have determined to be reportable
segments: Wolverine
Michigan Group and Wolverine Boston Group. Please tell us the title
and describe the
role of the CODM and each of the individuals who report to the CODM.
We note from
your website that management includes Presidents of certain brands
such as Saucony,
Merrell, Sperry & Keds, Wolverine Boot Group, and Sweaty Betty, as
well as a President
of International and President of Global eCommerce. Please explain to
us the role of each
of these Presidents and how they report to the CODM. Additionally,
please provide us the
following information:
Tell us how often the CODM meets with his/her direct reports, the
financial
information the CODM reviews to prepare for those meetings, the
financial
information discussed in those meetings, and who else attends
those meetings;
Tell us who is held accountable for Wolverine Michigan Group and
Wolverine
Boston Group and the title and role of the person this individual
reports to in the
organization;
Describe the information regularly provided to the CODM and how
frequently it is
prepared;
Describe the information regularly provided to the Board of
Directors and how
frequently it is prepared;
Explain how budgets are prepared, who approves the budget at each
step of the
process, the level of detail discussed at each step, and the
level at which the CODM
makes changes to the budget; and
Describe the basis for determining the compensation for each of
the individuals that
report to the CODM.
Michael Stornant
Wolverine World Wide, Inc.
May 31, 2022
Page 3
Form 10-Q for the Quarter Ended April 2, 2022
Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Known Trends Impacting Our Business, page 21
4. We note your disclosure that you expect certain aspects of the
disruption in the global
supply chain to continue into future periods and you will continue to
monitor delays and
other disruptions in the supply chain and will implement measures
intended to mitigate the
effects of such delays and disruptions as needed. Please revise to
discuss known trends or
uncertainties resulting from mitigation efforts undertaken, if any.
Explain whether any
mitigation efforts introduce new material risks, including those
related to product quality,
reliability, or regulatory approval of products.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Melissa Gilmore at (202) 551-3777 or Claire Erlanger at
(202) 551-
3301 with any questions.
FirstName LastNameMichael Stornant Sincerely,
Comapany NameWolverine World Wide, Inc.
Division of
Corporation Finance
May 31, 2022 Page 3 Office of
Manufacturing
FirstName LastName