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                            September 26, 2023

       Oliver Reichert
       Chief Executive Officer
       Birkenstock Holding Ltd
       1-2 Berkeley Square
       London W1J 6EA
       United Kingdom

                                                        Re: Birkenstock Holding
Ltd
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed September 15,
2023
                                                            File No. 333-274483

       Dear Oliver Reichert:

             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.
Unless we note
       otherwise, our references to prior comments are to comments in our
September 7, 2023 letter.

       Registration Statement on Form F-1 filed September 15, 2023

       Use of Proceeds, page 74

   1.                                                   Please disclose the
estimated net amount of the proceeds broken down into each principal
                                                        intended use thereof.
See Item 3.C of Form 20-F.
 Oliver Reichert
FirstName
BirkenstockLastNameOliver
            Holding Ltd Reichert
Comapany 26,
September  NameBirkenstock
               2023        Holding Ltd
September
Page 2     26, 2023 Page 2
FirstName LastName
Business
Operations
Logistics, page 149

2.       We note your response to comment 2, and reissue in part. Please tell
us whether you
         have a contractual agreement with the fulfillment center in Columbus,
Ohio, and describe
         the material terms of any agreement you have with that facility.
Tax Receivable Agreement, page 179

3.       We note your response to comment 3. Please revise your disclosure to
include a
         representation that all material terms of the agreement have been
discussed. Please make
         similar revisions to your disclosure regarding the Shareholders'
Agreement.
Exhibits and Financial Statement Schedules.
Form of Opinion of Carey Olsen Jersey LLP, page II-1

4.       Please have counsel file a final opinion in a pre-effective amendment
to the registration
         statement. In addition, please have counsel revise to:
             remove assumption 3.1.5. Counsel may not assume that the company
is not insolvent;
             revise paragraph 4 to recognize that the shares to be sold by the
selling shareholder
              are already outstanding and fully paid; and
             remove "the Directors" designation from the addressee as it,
combined with the
              statement in paragraph 6.3, creates an improper limitation on
reliance.

       You may contact Charles Eastman at 202-551-3794 or Martin James at
202-551-3671 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Erin Donahue at 202-551-6063 or Erin Purnell at 202-551-3454 with any
other
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Manufacturing
cc:      Ross Leff