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February
11, 2008
MEMORANDUM
VIA
EDGAR AND FACSIMILE
Ms.
Linda
Cvrkel
Branch
Chief
Securities
and Exchange Commission
Division
of Corporation Finance
Washington,
D.C. 20549-0305
For
Commission Use
Only
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RE:
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Johnson
Outdoors Inc.
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Form
10-K for the Fiscal Year Ended September 28, 2007
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File
No. 000-16255
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Dear
Ms.
Cvrkel:
The
following is the response of Johnson Outdoors Inc. (the “Company”) to the
comments in the letter of the Staff of the Securities and Exchange Commission,
dated January 31, 2008 (the “Comment Letter”), received by the Company on the
same date, relating to the Company’s Form 10-K for the fiscal year ended
September 28, 2007. The numbered response set forth below corresponds
to the numbered paragraph in the Comment Letter. Following the
comment, we provide our response (in regular type). If you would like
to discuss our response, you may contact David Johnson, Vice President and
Chief
Financial Officer of the Company, at (262) 631-6640 or Derek Coffie, Corporate
Controller of the Company, at (262) 631-6698.
FORM
10-K FOR THE YEAR ENDED
SEPTEMBER 28, 2007
Note
15. Significant Event,
page F-29
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1.
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We
note
from your response to our prior comment number 12 that you have
inappropriately classified $736,098 of insurance proceeds received
during
fiscal 2006 and 2007 that were related to property and equipment
losses
during 2006 as cash flows from operating activities in our consolidated
statements of cash flows. We also note from your response that
you will revise future filings to reclassify these insurance proceeds
as
investing activities in your consolidated statements of cash
flows. As the misclassifications of insurance proceeds in your
consolidated statements of cash flows for fiscal 2006 and 2007 represent
errors that appear to be somewhat material in relation to your operating
cash flows for each of these periods, please confirm that you will
also
provide the disclosures required by paragraph 26 of SFAS No. 154
in the
notes to your financial statements with respect to the
reclassifications.
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We
note
the Staff’s comment and confirm that the Company will provide disclosures
required by paragraph 26 of SFAS No. 154 in the notes to our financial
statements with respect to the reclassifications related to the
misclassifications of insurance proceeds.
*
*
*
The
Company appreciates the Staff’s comments and trusts the above discussion
satisfactorily answers all questions raised.
Very
truly yours,
/s/
David W. Johnson
David
W.
Johnson
Vice
President and Chief Financial Officer
cc: Claire
Erlanger, Securities and Exchange Commission
James
Bedore, Reinhart Boerner Van Deuren s.c.
Eric
Hagemeier, Reinhart Boerner Van Deuren s.c.
Kevin
Klimara, Ernst & Young LLP
Stephen
Mackey, Ernst & Young LLP
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