View:
United States securities and exchange commission logo
July 12, 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
Response dated June
27, 2022
File No. 001-06024
Dear Mr. Stornant:
We have reviewed your June 27, 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
May 31, 2022 letter.
Response Letter Dated June 27, 2022
Note 18. Business Segments, page 66
1. We note your response
to our prior comment 3 and have the following additional
comments:
We note that the
Monthly Internal Financial Statements which are provided to the
CODM weekly,
include brand information. Please specifically describe the type of
brand information
included in this report. We note from your response that the
CODM generally did
not use this brand information to allocate resources or evaluate
performance. Please
tell us if there are any times that he does use brand information
to allocate
resources or evaluate performance.
Michael Stornant
Wolverine World Wide, Inc.
July 12, 2022
Page 2
We note from your response that Mr. Hoffman uses the brand
information in the
Monthly Internal Financial statements to assess and explain the
performance of the
operating segments and to make resource allocation decisions
within the operating
segments. Please explain to us the nature of the brand
information used by Mr.
Hoffman, how often he receives it and tell us how his use of this
information differs
from the use by the CODM. Also, please tell us if Mr. Hoffman
holds regular
meetings with the Brand Presidents/GMs and if so describe the
frequency of these
meetings and the nature of any financial information discussed
during the meetings.
We note that Mr. Hoffman also oversaw the Company s
International Group and
eCommerce group. Please explain to us the nature of his role in
overseeing these
groups, include the nature of any financial information provided
by these groups that
he reviews. Please also explain to us the nature of Mr. Hoffman
s role in the
budgeting process.
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
July 12, 2022 Page 2 Office of
Manufacturing
FirstName LastName