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                             December 6, 2022

       David Callen
       Executive Vice President and Chief Financial Officer
       Sleep Number Corp
       1001 Third Avenue South
       Minneapolis, Minnesota 55404

                                                        Re: Sleep Number Corp
                                                            Form 10-K for the
year ended January 1, 2022
                                                            Form 10-Q for the
period ended October 1, 2022
                                                            File No. 0-25121

       Dear David Callen:

              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-Q for the period ended October 1, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Non-GAAP Data Reconciliations
       Return on Invested Capital (ROIC), page 23

   1.                                                   We note you include
adjustments in arriving at net operating profit after taxes that appear
                                                        to remove your
operating lease rent expense under GAAP and replace it with estimated
                                                        depreciation and
include lease adjustments in arriving at average invested capital. As this
                                                        appears to be an
individually tailored revenue recognition measurement method, please
                                                        remove from your filing
or advise. Refer to Question 100.04 of the Non-GAAP Financial
                                                        Measures Compliance and
Disclosure Interpretations. This issue also applies to your
                                                        earnings release
included in Form 8-K filed on October 26, 2022.

       Form 10-K for the period ended January 1, 2022
 David Callen
Sleep Number Corp
December 6, 2022
Page 2
Management's Discussion and Analysis of Results of Operation and Financial
Condition
Comparison of 2021 and 2020, page 37

2.       We note your discussion of multiple drivers for changes in Gross
Profit including a
         partial offset comprised of "price increases to offset inflation
pressures, combined with a
         more favorable sales mix of higher-margin products." In future
filings, where you describe
         two or more factors that contributed to a material change in a
financial statement line item
         between periods including offsetting factors, please quantify each
material factor that
         contributed to the overall change in that line item. In addition, to
the extent that inflation
         is a material driver, please also disclose actions planned or taken to
mitigate inflationary
         pressure. Refer to Item 303 of Regulation S-K and Section III.D of SEC
Release No. 33-
         6835. As part of your response, provide us with examples of your
intended disclosures
         based on current financial results.
Revenue Recognition, page 63

3.       We note from page 4 that you offer various product categories,
including 360 Smart Beds,
         FlexFit adjustable bases, and Bedding, as well as other products.
Please tell us how you
         considered the guidance in ASC 606-10-50-5 and ASC 606-10-55-89
through 55-91 when
         evaluating whether to disclose disaggregated revenue by product
categories in addition to
         revenue by sales channel in the notes to your financial statements.
       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 Claire Erlanger at
(202) 551-
3301 with any questions.



FirstName LastNameDavid Callen                                  Sincerely,
Comapany NameSleep Number Corp
                                                                Division of
Corporation Finance
December 6, 2022 Page 2                                         Office of
Manufacturing
FirstName LastName