SecProbe.io

May 4, 2011

Via E-mail
Mr. Kevin A. Plank, President Under Armour, Inc. 1020 Hull Street Baltimore, Maryland 21230
Re: Under Armour, Inc.
 Form 10-K for Fiscal Year End December 31, 2010
Filed February 24, 2011 File No. 001-33202

Dear Mr. Plank:
 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Form 10-K for the Fiscal Year Ended December 31, 2010

 Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations, page 26

1. Please also provide a separate  discussion in your Management’s Discussion and Analysis
of the reasons for changes in the operating re sults of each of your segments.  In addition,
where there is more than one reason for a change between periods, please quantify the
extent to which each reason contributed to the overall change.  See Item 303(A)(3) of
Regulation S-K.  Please provide us  the text of your proposed di sclosures to be included in
future filings based on the December 31, 2010 results.
 Year Ended December 31, 2010 Compared to Year Ended December 31, 2009, page 29

2. We note that your allowance for doubtful accounts decreased to 4.8% of accounts
receivable as of December 31, 2010 from 6.5%  of accounts receivable in 2009.  Schedule

Kevin A. Plank Under Armour, Inc. May 4, 2011 Page 2

 II on page 77 shows that $190,000 was charged to the expense for the allowance for
doubtful accounts in the year ended Decembe r 31, 2010 compared to $1.6 million in
2009.  Please explain the reasons for the decreas e in the reserve and any changes in your
policy for estimating collectabili ty of accounts receivable.  Include a discussion of known
trends that are having a materi al effect on your results and ex plain management’s view of
the significant underlying fact ors causing these trends so th at readers can ascertain the
likelihood that past performance is indicative of future performance.   See Section III of
our Release 33-8350.
 Notes to Consolidated Financial Statements, page 49

16. Segment Data and related Information, page 67

3. In 2010 your operating segments changed to reflect how the chief operating decision
maker (“CODM”) makes decisions about alloca ting resources and assessing performance.
We note that your operating segments are base d on geographic regions:  North America,
Latin America, Europe, the Middle East and Af rica.  Please explain to us your internal
reporting structure (e.g. divisi ons, business units etc.) and the manner in which you
manage your business.  Tell us if certain se gment managers are responsible for specific
product categories in addition to geographic ar eas.  Please tell us how you analyzed the
guidance of ASC 280-10-50-9 in  the identification of your  operating segments.

4. We note that 94% of your revenues are in th e North American segment.  We also note
that your discussion in your quarterly earni ngs release discussed revenues and gross
margins for the direct-to-consumer channe l and the various product category.  Please
explain whether you have discrete financial information by channel and product category.
Please discuss if you are aggreg ating any segments in your North America segment and if
so discuss how you meet the aggrega tion criteria in ASC 280-10-50-11.
 5. We note your Executive Team as disclosed on yo ur website.  Please explain the nature of
the roles of the Executive Vice President of Product, Senior Vice President of Footwear,
and Senior Vice President of A pparel as they relate to the alignment of your segments.
Please tell us whether these roles are functiona l or whether they repr esent actual divisions
within your organization.  Please also tell  us whether any of these individuals is
compensated based upon the performance of their division. Please explain to us the
relative rank of thes e positions with respect to the CODM.

6. We note that your Executive Team added an Executive Vice President of Global Brand
and President of Internationa l, effective February 1, 2011.  Please explain your internal
reporting structure on your international opera ting segments for the year ended December
31, 2010.
 7. Please identify your CODM and provide us w ith the financial information regularly
reviewed by the CODM to assess performance and allocate resources for the year ended
December 31, 2010.  If multiple levels of fi nancial information are provided to the

Kevin A. Plank Under Armour, Inc. May 4, 2011 Page 3

 CODM, please provide us with each level and explain how the CODM utilizes the
financial information.
 Exhibits

8. We note that Exhibits 10.03, 10.08, 10.12, 10.15, 10.18, and 10.24 appear to be missing
schedules, attachments and /or exhibits.  We also note that Exhibits 10.23A, 10.23B, and
10.23C to the Form 10-K filed on February  22, 2008, Exhibits 10.02, 10.03 to the Form
10-Q filed on August 6, 2008, Exhibits 10.02 and 10.03 to the Form 10-Q filed on May 7, 2009, Exhibits 10.21 and 10.22 to the Form 10-K filed on February 25, 2010, Exhibit
10.03 to the Form 10-Q filed on May 5, 2010, a nd Exhibit 10.02 to the Form 10-Q filed
on August 5, 2010,  appear to be missing e xhibits, schedules a nd/or attachments.   Please
confirm that you will file these exhibits in their entirety wi th your next periodic report.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Brian McAllister at (202)  551-3341 or Nasreen Mohammed, Assistant
Chief Accountant, at (202) 551-3773 if you have questions regarding comments on the financial
statements and related matters.  Please cont act Shehzad Niazi at ( 202) 551-3121 or Pamela
Howell, Special Counsel, at (202) 551-3357 with any other questions.

Sincerely,
   /s/ Pamela Howell  for

John Reynolds Assistant Director