United States securities and exchange commission logo

                             April 28, 2021

       Rene Casares
       Senior Vice President, General Counsel and Secretary
       Academy Sports & Outdoors, Inc.
       1800 North Mason Road
       Katy, TX 77449

                                                        Re: Academy Sports &
Outdoors, Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted April 23,
                                                            CIK No. 0001817358

       Dear Mr. Casares:

                                                        This is to advise you
that we do not intend to review your registration statement.

               We request that you publicly file your registration statement no
later than 48 hours prior
       to the requested effective date and time. Please refer to Rules 460 and
461 regarding requests for
       acceleration. 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.

                                                        Please contact Nicholas
Lamparski at 202-551-4695 with any questions.


                             Division of Corporation Finance

                             Office of Trade & Services
       cc:                                              Joseph H. Kaufman