View:
United States securities and exchange commission logo
February 28, 2023
Deana McPherson
Executive Vice President and Chief Financial Officer
Smith & Wesson Brands, Inc.
2100 Roosevelt Avenue
Springfield, MA 01104
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
Dear Deana McPherson:
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 April 30, 2022
Management's Discussion and Anlaysis 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.
Deana McPherson
Smith & Wesson Brands, Inc.
February 28, 2023
Page 2
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.
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.
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 Charles Eastman at 202-551-3794 or Andrew Blume at
202-551-
3254 with any questions.
FirstName LastNameDeana McPherson Sincerely,
Comapany NameSmith & Wesson Brands, Inc.
Division of
Corporation Finance
February 28, 2023 Page 2 Office of
Manufacturing
FirstName LastName