United States securities and exchange commission logo September 4, 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. 2 to Draft Registration Statement on Form S-1 Submitted September 1, 2020 CIK No. 0001817358 Dear Mr. Hicks: We have reviewed your amended draft registration statement and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to this comment and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 2 to Draft Registration Statement on Form S-1 Our Performance Improvement Initiatives, page 4 1. We note the statement from your response to our prior comment letter dated August 26, 2020, that "it is difficult to ascertain with precision what portion of its increased comparable sales during the first half of 2020 is attributable to the increase in e- commerce sales due to the COVID-19 pandemic as compared to the impact of the business improvements... ." Please include similar disclosure in your registration statement. Ken C. Hicks FirstName LastNameKen C. Hicks Academy Sports & Outdoors, Inc. Comapany 4, September NameAcademy 2020 Sports & Outdoors, Inc. September Page 2 4, 2020 Page 2 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. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Joseph Kaufman, Esq.