United States securities and exchange commission logo





                              May 31, 2022

       Michael Stornant
       Chief Financial Officer
       Wolverine World Wide, Inc.
       9341 Courtland Drive N.E.
       Rockford, MI 49351

                                                        Re: Wolverine World
Wide, Inc.
                                                            Form 10-K for the
Fiscal Year Ended January 1, 2022
                                                            Form 10-Q for the
Quarter Ended April 2, 2022
                                                            File No. 001-06024

       Dear Mr. Stornant:

              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 January 1, 2022

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       2021 Financial Overview, page 25

   1.                                                   We note the disclosure
of your growth in eCommerce and direct-to-consumer revenue
                                                        from period to period
on a percentage basis. We also note these growth percentages in
                                                        your earnings release
presentations as well as related investor presentations. Please tell us
                                                        your consideration of
disclosing the dollar amounts of related revenue for each of these
                                                        revenue streams in your
earnings presentations and annual and periodic filings as it
                                                        appears such
information would be meaningful to investors. Refer to Item 303 of
                                                        Regulation S-K.
Additionally, please clarify the nature of any differences between
                                                        revenue categorized as
"direct-to-consumer revenue," "consumer-direct revenue" and
                                                        "eCommerce revenue" as
all three of these labels appear in your filings.
 Michael Stornant
FirstName  LastNameMichael
Wolverine World  Wide, Inc. Stornant
Comapany
May        NameWolverine World Wide, Inc.
     31, 2022
May 31,
Page 2 2022 Page 2
FirstName LastName
Notes to Consolidated Financial Statements
6. Revenue from Contracts with Customers, page 50

2.       We note you disaggregate revenue by segment and by wholesale vs.
consumer direct
         channels. Please tell us what consideration you gave to further
disaggregation by brand
         and further disclosure for your e-Commerce channels. For example, in
certain of your
         investor presentations and earnings releases, you present revenue by
brand in percentages,
         and in dollars for the first fiscal quarter ended April 2, 2022,
whereas only percentage
         change was provided previously. You also present revenue growth
percentages for DTC
         revenue and for eCommerce and Stores for each of your brands where
applicable. Refer
         to the guidance in ASC 606-10-50-5 and related implementation guidance
in ASC 606-10-
         55-90 and 91.
18. Business Segments, page 66

3.       We note your disclosure in Note 18 that your portfolio of brands is
organized into two
         operating segments which you have determined to be reportable
segments: Wolverine
         Michigan Group and Wolverine Boston Group. Please tell us the title
and describe the
         role of the CODM and each of the individuals who report to the CODM.
We note from
         your website that management includes Presidents of certain brands
such as Saucony,
         Merrell, Sperry & Keds, Wolverine Boot Group, and Sweaty Betty, as
well as a President
         of International and President of Global eCommerce. Please explain to
us the role of each
         of these Presidents and how they report to the CODM. Additionally,
please provide us the
         following information:
             Tell us how often the CODM meets with his/her direct reports, the
financial
              information the CODM reviews to prepare for those meetings, the
financial
              information discussed in those meetings, and who else attends
those meetings;
             Tell us who is held accountable for Wolverine Michigan Group and
Wolverine
              Boston Group and the title and role of the person this individual
reports to in the
              organization;
             Describe the information regularly provided to the CODM and how
frequently it is
              prepared;
             Describe the information regularly provided to the Board of
Directors and how
              frequently it is prepared;
             Explain how budgets are prepared, who approves the budget at each
step of the
              process, the level of detail discussed at each step, and the
level at which the CODM
              makes changes to the budget; and
             Describe the basis for determining the compensation for each of
the individuals that
              report to the CODM.
 Michael Stornant
Wolverine World Wide, Inc.
May 31, 2022
Page 3
Form 10-Q for the Quarter Ended April 2, 2022

Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Known Trends Impacting Our Business, page 21

4.       We note your disclosure that you expect certain aspects of the
disruption in the global
         supply chain to continue into future periods and you will continue to
monitor delays and
         other disruptions in the supply chain and will implement measures
intended to mitigate the
         effects of such delays and disruptions as needed. Please revise to
discuss known trends or
         uncertainties resulting from mitigation efforts undertaken, if any.
Explain whether any
         mitigation efforts introduce new material risks, including those
related to product quality,
         reliability, or regulatory approval of products.
       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 Melissa Gilmore at (202) 551-3777 or Claire Erlanger at
(202) 551-
3301 with any questions.



FirstName LastNameMichael Stornant                            Sincerely,
Comapany NameWolverine World Wide, Inc.
                                                              Division of
Corporation Finance
May 31, 2022 Page 3                                           Office of
Manufacturing
FirstName LastName