Mail Stop 0308



May 13, 2005

John F. Wittkowske
Senior Vice President and Chief Financial Officer
Weyco Group, Inc.
333 W. Estabrook Boulevard,
P.O. Box 1188
Milwaukee, WI  53201

		RE: 	Weyco Group, Inc.
			Form 10-K for the fiscal year ended December 31,
2004
			Form 10-Q for the quarter ended March 31, 2005
			File No.  0-9068

Dear Mr. Wittkowske:

	We have reviewed the responses in your letter filed on April
29,
2005 and have the following additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

      *	*	*	*

Consolidated Financial Statements and Notes to Consolidated
Financial
Statements

Note 2. Summary of Significant Accounting Policies

1. Reference is made to our prior comment (4) and your response.
Please also include in your disclosure in future filings the fact
that all of your subsidiaries included in the consolidated
financial
statements are wholly-owned.


Note 16.  Segment Information

2. We have read your response to our prior comment (6).  Please
specifically tell us and disclose whether operating segments have
been aggregated.  See paragraph 26.a of SFAS 131.  If so, advise
us
of your basis for aggregation.

      *	*	*	*

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a letter that keys your responses to our comments
and
provides any requested supplemental information.  Detailed
response
letters greatly facilitate our review.  Please file your response
letter on EDGAR.  Please understand that we may have additional
comments after reviewing your responses to our comments.

      If you have any questions regarding these comments, please
direct them to Dave Irving, Staff Accountant, at (202) 551-3321
or,
in his absence, to Donna Di Silvio, at (202) 551-3202, or the
undersigned at (202) 551-3841.  Any other questions regarding
disclosure issues may be directed to H. Christopher Owings,
Assistant
Director, at (202) 551-3725.

      Sincerely,



      Michael Moran
      Branch Chief
??

??

??

??

Mr. John F. Wittkowske
Weyco Group, Inc.
Page 2 of 2


2