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                                                           August 6, 2018

Brian P. Lynch
Chief Financial Officer
Callaway Golf Company
2180 Rutherford Road
Carlsbad, California 92008

       Re: Callaway Golf Company
           Form 10-K for the Year Ended December 31, 2017
           Form 10-Q for the Quarter Ended March 31, 2018
           File No. 001-10962

Dear Mr. Lynch:

       We have reviewed your filings 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-K for the Year Ended December 31, 2017

Notes to Consolidated Financial Statements
Note 4. Financing Arrangements, page F-20

1.    We note your disclosure on page F-20 that your ABL Facility imposes
restrictions on the
      amount the company could pay in annual cash dividends. In addition, we
note you
      removed the disclosure related to the maximum amount that the company
could have paid
      out in dividends that was included in the 2016 Form 10-K. Please provide
us with your
      analysis on how your current disclosure complies with Rule 4-08(e) of
Regulation S-X
      and revise your future disclosure as necessary.
 Brian P. Lynch
Callaway Golf Company
August 6, 2018
Page 2
Form 10-Q for the Quarter Ended March 31, 2018

Notes to Consolidated Condensed Financial Statements
Note 2. Revenue Recognition, page 12

2.       Please disclose how any transaction-related taxes are factored into
the determination of
         your transaction prices pursuant to ASC 606-10-32-2A, including
whether you have
         elected to exclude all taxes assessed by a governmental authority from
the measurement
         of the transaction prices that are imposed on your products.
3.       Please tell us and consider disclosure of your accounting policy
election to account for
         shipping and handling activities. Please refer to ASC 235-10-50-1
through 6 and ASC
         606-10-25-18B.
Note 9. Investments
Investment in Topgolf International Inc., page 21

4.       We note your disclosure that as of March 31, 2018 your investment in
Topgolf was
         accounted for as cost less impairments as its fair value is not
readily determinable. We
         further note your disclosure that, based on observable market
transactions prior to
         December 31, 2017, the company believes that the fair value of the
investment
         significantly exceeds its cost. Please tell us the basis of this fair
value statement and
         clarify why you have concluded your investment should be accounted for
at cost less
         impairments as opposed to fair value.
        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
action by the staff.

      You may contact Melissa Gilmore at (202) 551-3777 or Melissa Raminpour at
(202) 551-
3379 with any questions.



FirstName LastNameBrian P. Lynch                               Sincerely,
Comapany NameCallaway Golf Company
                                                               Division of
Corporation Finance
August 6, 2018 Page 2                                          Office of
Transportation and Leisure
FirstName LastName
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