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September 20, 2023
Jon Baker
Chief Executive Officer
Sportsman’s Warehouse Holdings, Inc.
1475 West 9000 South Suite A
West Jordan, Utah 84088
Re:Sportsman’s Warehouse Holdings, Inc.
Form 10-K for the Fiscal Year Ended January 28, 2023
Filed April 13, 2023
File No. 1-36401
Dear Jon Baker:
            We have reviewed your filing 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended January 28, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 53
1.We note your reconciliation of Adjusted EBITDA here and in your press releases on
Forms 8-K includes an adjustment for pre-opening expenses and that you have incurred
these costs in every period from 2013 on. Please tell us how you determined that these
costs are not normal, recurring, cash operating expenses. Refer to Question 100.01 of the
Non-GAAP Financial Measures Compliance and Disclosure Interpretations.
Consolidated Statement of Income, page 60
2.We note that you present gross profit which excludes depreciation and amortization
expense. Please tell us your consideration of labeling cost of goods sold (exclusive of
depreciation and amortization).  Also, tell us your consideration of not reporting a figure
for income before depreciation in your statements of income. Refer to SAB Topic 11:B.

 FirstName LastNameJon Baker
 Comapany NameSportsman’s Warehouse Holdings, Inc.
 September 20, 2023 Page 2
 FirstName LastName
Jon Baker
Sportsman’s Warehouse Holdings, Inc.
September 20, 2023
Page 2
            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.
            You may contact Tony Watson at (202) 551-3318 or Joel Parker at (202) 551-3651 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services