TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo October 3, 2023 Oliver Reichert Chief Executive Officer Birkenstock Holding Ltd 1-2 Berkeley Square London W1J 6EA United Kingdom Re: Birkenstock Holding Ltd Amendment No. 2 to Registration Statement on Form F-1 Filed October 2, 2023 File No. 333-274483 Dear Oliver Reichert: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our September 26, 2023 letter. Amendment No. 2 to Registration Statement on Form F-1 filed on October 2, 2023 Capitalization, page 78 1. Revise the adjusted column of the table to remove your cash and cash equivalents of 289,609 from the amount currently presented as ''Total shareholders equity and indebtedness". Further, please revise to title the caption "total capitalization". Oliver Reichert FirstName BirkenstockLastNameOliver Holding Ltd Reichert Comapany October NameBirkenstock Holding Ltd 3, 2023 October Page 2 3, 2023 Page 2 FirstName LastName Please 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