TEXT-EXTRACT 2 filename2.txt 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