United States securities and exchange commission logo
September 25, 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
Registration Statement on Form S-1
Filed September 23,
2020
File No. 333-248683
Dear Mr. Hicks:
We have reviewed your amended registration statement 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 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
response.
After reviewing any amendment to your registration statement and
the information you
provide in response to these comments, we may have additional comments.
Amendment No. 1 to Registration Statement on Form S-1 filed September
23, 2020
Summary Historical Consolidated Financial and Other Data, page 16
1. The balance sheet data
for all periods other than as of August 1, 2020 is missing from
your table on page 17.
Please provide a completed table in your next amendment, as it
appears that all of the
data for completing the table is available.
Dilution, page 61
2. Please revise the
calculation of your pro forma net tangible book (deficit) as of August 1,
2020, and your
resultant calculation of dilution per share of common stock to investors in
the offering, to also
give pro forma effect to the $257 million special distribution paid to
existing unitholders on
August 25, 2020.
Ken C. Hicks
Academy Sports & Outdoors, Inc.
September 25, 2020
Page 2
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,
FirstName LastNameKen C. Hicks
Division of
Corporation Finance
Comapany NameAcademy Sports & Outdoors, Inc.
Office of Trade &
Services
September 25, 2020 Page 2
cc: Joseph Kaufman, Esq.
FirstName LastName