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                              March 15, 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
                                                            Response dated
March 10, 2023
                                                            File No. 001-31552

       Dear Deana McPherson:

              We have reviewed your March 10, 2023 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
       February, 28, 2023 letter.

       Form 10-K for the Fiscal Year Ended April 30, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 38

   1.                                                   We note your response
to comment 1 and have the following comments:

                                                              Please confirm
that when you describe two or more business reasons that contributed
                                                            to a material
change in any financial statement line item between periods, you will
                                                            quantify, where
possible, the extent to which each change contributed to the overall
                                                            change in that line
item.

                                                              In regards to
your sales fluctuations, explain to us in greater detail why you are not
 Deana McPherson
Smith & Wesson Brands, Inc.
March 15, 2023
Page 2
              able to quantify changes attributable to prices and volumes. In
doing so, clarify if
              certain price and/or volume information is not available or not
provided at a certain
              level of specificity. If you conclude such information is not
calculable, quantify the
              price and volume information that is determinable, such as
material product line
              discontinuations, and better describe the relative significance
of the factors impacting
              sales fluctuations.

       You may contact Charles Eastman at 202-551-3794 or Andrew Blume at
202-551-3254 if
you have any questions.



FirstName LastNameDeana McPherson                               Sincerely,
Comapany NameSmith & Wesson Brands, Inc.
                                                                Division of
Corporation Finance
March 15, 2023 Page 2                                           Office of
Manufacturing
FirstName LastName