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.