June 28, 2019

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

       Re: Sleep Number Corporation
           Form 10-Q for Fiscal Quarter Ended March 31, 2019
           Filed April 26, 2019
           File No. 000-25121

Dear Mr. Callen:

       We have reviewed your filing 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 Fiscal Quarter Ended March 31, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Data, page 18

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. Please
      tell us your basis for including each of these adjustments, how you
determined the amount
      of these adjustments, how the adoption of ASC 842 was considered for
continuing to
      present these adjustments and how your presentation complies with the
guidance in
      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 April 17, 2019.
       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
 David Callen
Sleep Number Corporation
June 28, 2019
Page 2

action by the staff.

       You may contact Tracie Mariner, Staff Accountant, at (202) 551-3744, or
Melissa Rocha,
Senior Assistant Chief Accountant, at (202) 551-3854, if you have questions
regarding
comments on the financial statements and related matters.



                                                         Sincerely,
FirstName LastNameDavid Callen
                                                         Division of
Corporation Finance
Comapany NameSleep Number Corporation
                                                         Office of
Manufacturing and
June 28, 2019 Page 2                                     Construction
FirstName LastName