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United States securities and exchange commission logo
August 23, 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 8-K furnished
August 10, 2022
Response dated July
25, 2022
File No. 001-06024
Dear Mr. Stornant:
We have reviewed your July 25, 2022 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
July 12, 2022 letter.
Response letter Dated July 26, 2022
Note 18. Business Segments, page 66
1. Please tell us and
disclose the factors used in determining you have two operating and
reportable segments.
Refer to ASC 280-10-50-21. Please explain in detail how the lower-
level operating results
(e.g., net revenues and gross profit) included in your Monthly
Internal Financial
Statements provided to the CODM and the revenue information by
brand provided in your
earnings release are not indicative of your operating segments
being at a lower level
than your reportable segments.
2. We note from your
response to comment one that the brand information included in your
Monthly Internal
Financial Statements included Net Revenue; Gross Profit; Selling,
Michael Stornant
Wolverine World Wide, Inc.
August 23, 2022
Page 2
General and Administrative Expense; and Pre-Tax Earnings. Please
provide us with Net
Revenue and Gross Profit information by brand for the periods
presented in your filing.
To the extent there is variation in profit margins across your various
brands, please
provide a discussion regarding whether or not this indicates that the
brands have dissimilar
economic characteristics.
3. You state in your response that Mr. Hoffman meets with brand
presidents to discuss the
specific brands products in the current market and future products,
marketing programs
and inventory demand planning. Please tell us who makes key operating
decisions on an
ongoing basis, including those decisions relating to generation of
revenue and incurrence
of expenses. Discuss the information that is used to make these
decisions.
4. Please describe the compensation arrangements of the brand presidents
and general
managers, including the portion of their compensation that is based on
the results of the
brand and the significance of that brand s performance relative to
other benchmarks. In
addition, describe Mr. Hoffman s compensation arrangement in greater
detail.
5. We note that your process to prepare the budget includes a detailed
process built up to the
operating segments and consolidated level. Please tell us if budgets
are prepared for each
of your brands and, if so, who prepares and approves the brand
budgets.
Form 8-K furnished August 10, 2022
Exhibit 99.1 Earnings Release, page 11-12
6. We note that the Non-GAAP measures Adjusted Operating Profit, Adjusted
Operating
Margin, and Adjusted EPS for the Q2 2021 period, include an adjustment
for air freight
charges related to production and shipping delays caused by the
COVID-19 pandemic.
While the increases may have been perceived as temporary, we believe
your inbound and
outbound freight costs represent a normal and recurring operating
expense and is not an
appropriate adjustment when considering Question 100.01 of the C&DI on
non-GAAP
Financial Measures. Please revise to remove these adjustments.
You may contact Melissa Gilmore at (202) 551-3777 or Claire Erlanger at
(202) 551-
3301 if you have any questions.
FirstName LastNameMichael Stornant Sincerely,
Comapany NameWolverine World Wide, Inc.
Division of
Corporation Finance
August 23, 2022 Page 2 Office of
Manufacturing
FirstName LastName