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