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                             December 16, 2022

       David Foulkes
       Chief Executive Officer
       Brunswick Corporation
       26125 N. Riverwoods Blvd., Suite 500
       Mettawa, IL 60045-3420

                                                        Re: Brunswick
Corporation
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Filed February 16,
2022
                                                            File No. 001-01043

       Dear David Foulkes:

              We have reviewed your December 5, 2022 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
       November 18, 2022 letter.

       Form 10-K for the Fiscal Year Ended December 31, 2021

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 32

   1.                                                   We note your response
to prior comment 3. Please further revise your disclosures to
                                                        provide additional
quantification regarding the effect of each factor identified as
                                                        impacting SG&A expense
as a percentage of revenue. For example, your analysis
                                                        currently states that
the increase in SG&A expense during the nine months ended October
                                                        1, 2022 reflects the
impact of 2021 acquisitions, increased spending on sales and
                                                        marketing, ACES
programs, and other growth initiatives, partially offset by increased net
                                                        sales, but does not
appear to quantify the impact of such changes. Also, refrain from using
                                                        terms such as
"primarily" in lieu of providing more specific quantitative disclosure. Refer
                                                        to Item 303(b) of
Regulation S-K.
 David Foulkes
Brunswick Corporation
December 16, 2022
Page 2
Notes to Consolidated Financial Statements
Note 6. Segment Information, page 73

2.    Please address the following as it relates to your response to prior
comment 7:
          Provide a more detailed description of the type of products sold by
each of the P&A
          operating segments as referenced in Note 5, and tell us how you
determined that the
          nature of such products is similar. In this regard, explain how
consumables sold by
          the Engine Parts and Accessories operating segment, such as engine
oils and
          lubricants and marine parts and accessories are similar to the
products sold by the
          ASG operating segment, such as marine electronics and control
systems, instruments,
          trolling motors, fuel systems, and electrical systems, as well as
specialty vehicle,
          mobile, and transportation aftermarket products.
          Explain further your statement that the ASG operating segment sells
and distributes
          products similar to Engine P&A products within the Attwood, RELiON,
and Power
          Products businesses and tell us how significant these businesses are,
both
          quantitatively and qualitatively, to the ASG operating segment.
          Provide us with the actual operating margin information for each
historical and
          forecasted period considered in your analysis (including to date in
fiscal 2022)
          separately for each of the Engine P&A and ASG operating segments.
          Tell us the additional financial information considered when
evaluating the economic
          characteristics of each of these operating segments and at a minimum
provide a
          quantified discussion of the gross margins and revenue separately for
each.
          Explain further your statement that overall operating margins by
product group and
          product types are generally consistent within each of the individual
operating
          segments. In your response, provide a breakdown of operating margins
by each
          product group and product type within each of the two operating
segments.
          Explain further how you considered the production processes are
similar for each
          operating segment. For example, tell us whether both operating
segments share
          the same or similar production facilities and equipment, work force,
or raw materials.

      You may contact Chen Chen, Staff Accountant, at 202-551-7351 or Kathleen
Collins,
Accounting Branch Chief at 202-551-3499 with any questions.



                                                           Sincerely,
FirstName LastNameDavid Foulkes
                                                           Division of
Corporation Finance
Comapany NameBrunswick Corporation
                                                           Office of Technology
December 16, 2022 Page 2
cc:       Ryan M. Gwillim
FirstName LastName