United States securities and exchange commission logo

                              August 26, 2020

       Ken C. Hicks
       President and Chief Executive Officer
       Academy Sports & Outdoors, Inc.
       1800 North Mason Road
       Katy, TX 77449

                                                        Re: Academy Sports &
Outdoors, Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted August
13, 2020
                                                            CIK No. 0001817358

       Dear Mr. Hicks:

             We have reviewed your amended registration statement and have the
       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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
August 7, 2020 letter.

       Amendment No. 1 to Draft Registration Statement on Form S-1

       Letter from our CEO, page iv

   1.                                                   Please characterize
your statement that "[w]e have a best-in-class value offering with
                                                        localized merchandising
and marketing, and a strategic footprint that sets us apart from
                                                        our competitors" as
your belief. Please also balance your disclosure that you have
                                                        achieved positive
comparable sales, and specifically three consecutive quarters with
                                                        positive comparable
sales, with the fact that you have experienced decreases in
                                                        comparable store sales
and net sales per square foot in each of the last three fiscal years.
                                                        Please also explain, as
appropriate, the extent to which the increase in comparable sales
                                                        are due to the
substantial increase in e-commerce sales experienced during the COVID-19
                                                        pandemic. Please make
similar revisions elsewhere as appropriate.
 Ken C. Hicks
Academy Sports & Outdoors, Inc.
August 26, 2020
Page 2

Who We Are, page 1

2.       We note your response to our prior comment 1. Please provide us
supplementally with
         support for the statement that you derived higher total revenue from
your stores in the
         southern United States than any other sporting goods and outdoor
recreation retailer in this
         region, as we were unable to verify this statement in the materials
previously provided.
3.       We note your response to our prior comment 2. Please disclose the
metrics you use to
         define a competitor as a "nearest" competitor, as it is unclear from
your definition how
         you selected four particular retailers. Additionally, please also
supplementally provide
         support for your fourth nearest competitor as we were unable to locate
it in the materials
Large and Loyal Customer Base, page 7

4.       We note your response to our prior comment 7, which stated that your
         include large format sporting goods stores and specialty outdoor
retailers (as such terms
         are defined on page 95). We also note that your disclosure on page 95
that states that your
         primary competitors are large format sporting goods stores and mass
general merchants.
         Please revise your disclosure on pages 7 and 98 to specifically
identify your competitors
         as large format sporting goods stores and specialty outdoor retailers.
Management's Discussion and Analysis
How We Assess the Performance of Our Business, page 69

5.       We note your response to our prior comment 12. Please confirm how you
allocate e-
         commerce sales among your comparable sales metric (i.e. equally
allocated among all
         stores, allocated to the store where the item was fulfilled, or
allocated to closest physical
         store if fulfilled by warehouse). Please describe whether your BOPIS
program is part of
         your e-commerce sales or in store sales.
FirstName LastNameKen C. Hicks
6.     We note your use of the term "footprint" throughout the filing,
including as a description
Comapany    NameAcademy
       of geographic          Sports
                      location,   store&size,
                                         Outdoors,   Inc.and product offerings.
Where appropriate,
Augustplease  revise
        26, 2020 Pageto 2clarify the meaning of this term.
FirstName LastName
 Ken C. Hicks
FirstName LastNameKen  C. Hicks
Academy Sports  & Outdoors, Inc.
August 26, NameAcademy
           2020         Sports & Outdoors, Inc.
Page 3 26, 2020 Page 3
FirstName LastName
       You may contact Patrick Kuhn at (202) 551-3308 or Linda Cvrkel at (202)
551-3813 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Cara Wirth at (202) 551-7127 or Erin Jaskot at (202) 551-3442 with any
other questions.


                                                           Division of
Corporation Finance
                                                           Office of Trade &
cc:      Joseph Kaufman, Esq.