Mail Stop 3561 								September 7, 2005 By U.S. Mail 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 have completed our review of your Form 10-K and related filings and have no further comments at this time. 							Sincerely, 							Michael Moran, Esq. Branch Chief