March 22, 2007
Mr. H. Christopher Owings
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549-7010
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549-7010
| Re: | Wellco Enterprises, Inc. Preliminary Proxy Statement (Amendment No. 1) Filed March 22, 2007 |
Dear Mr. Owings:
In connection with the filing today of Amendment No. 1 to our preliminary proxy statement, Wellco Enterprises, Inc. (the “Company”) hereby acknowledges that:
| • | the Company is responsible for the adequacy and accuracy of the disclosure in the filing; | ||
| • | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and | ||
| • | the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Thank you for your assistance with the filing.
Very truly yours,
/s/ V. Lee Ferguson
V. Lee Ferguson
President and Chief Executive Officer
President and Chief Executive Officer
cc: Stephen M. Lynch