March 6, 2006 via U.S. mail and facsimile Michael F. Golden President and Chief Executive Officer Smith & Wesson Holding Corporation 2100 Roosevelt Avenue Springfield, MA 01104 RE: Smith & Wesson Holding Corporation Form 10-K for the fiscal year ended April 30, 2005 Forms 10-Q for the fiscal quarters ended October 31, 2005 and July 31, 2005 File No. 1-31552 Dear Mr. Golden: We have completed our review of your Form 10-K and related filings and have no further comments at this time. If you have any further questions regarding our review of your filings, please contact Meagan Caldwell at (202) 551-3754 or, in her absence, Jeanne Baker, Assistant Chief Accountant at (202) 551- 3691. Sincerely, Rufus Decker Accounting Branch Chief ?? ?? ?? ?? Mr. Gary T. Steele March 9, 2005 Page 1 of 1 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE