United States securities and exchange commission logo September 7, 2021 Ken C. Hicks President and Chief Executive Officer Academy Sports & Outdoors, Inc. 1800 North Mason Road Katy, Texas 77449 Re: Academy Sports & Outdoors, Inc. Draft Registration Statement on Form S-1 Submitted September 1, 2021 CIK No. 000181758 Dear Mr. Hicks: 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 Scott Anderegg at 202-551-3342 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services