Mail Stop 3561

				August 9, 2005

James McDonald
Chief Financial Officer
Rocky Shoes and Boots, Inc.
39 East Canal Street
Nelsonville, OH 45764

		RE:	Rocky Shoes and Boots, Inc.
			File No. 0-21026
			Form 10-K for the year ended December 31, 2004
			Form 10-Q for the quarter ended March 31, 2005

Dear Mr. McDonald:

	We reviewed your response to our prior comment on the above
referenced filings as set forth in your letter dated August 4,
2005.
Our review resulted in the following accounting comment.

Form 10-K for the Year Ended December 31, 2004

1. Based on the information you provided it appears that the
following wholesale operating segments are quantitatively
significant
at the ten percent revenue level: Rocky - Manufactured, Rocky -
Sourced, and Wholesale Accessories combined.  Based on the
information you provided it appears that these operating segments
are
economically dissimilar and should not be aggregated.  Please
revise
your previous statement accordingly.  Finally, we agree with your
conclusion that you have separate military and retail reportable
segments.

	```````````````````````````````````````````````As
appropriate,
please respond to this comment within 10 business days or tell us
when you will provide us with a response.  Please provide us with
a
response letter that keys your response to our comment and
provides
any requested supplemental information.  Please file your response
letter on EDGAR as a correspondence file.






`
		If you have any questions regarding this comment, please
direct them to Robert Babula, Staff Accountant, at (202) 551-3339
or,
in his absence, to the undersigned at (202) 551-3841.  Any other
questions regarding disclosures issues may be directed to H.
Christopher Owings, Assistant Director at (202) 551-3725.





			Sincerely,



			Michael Moran, Esq.
			Branch Chief


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Mr. James McDonald
Rocky Shoes and Boots, Inc.
August 9, 2005
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