SecProbe.io

August 1, 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 Correspondence submitted June 1, 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. We note your response to comment one in our  letter dated May 4, 2011 regarding operating
results of each of your segments.  However, you have not fully addressed the comment.  Please provide an analysis of the reasons for increase in net sales and operating income and
where there is more than one reason for a cha nge between periods, please quantify the extent
to which each reason contributed to the overall change.  See Item 303(A)(3) of Regulation S-
K.

Kevin A. Plank, President  Under Armour, Inc. August 1, 2011 Page 2

 Notes to Consolidated Financial Statements, page 49

 16. Segment Data and Related Information, page 67

 2. We note your response to prior comment four in our letter dated Ma y 4, 2011 stating that you
have ten business units which are a mix of geogr aphies, products and di stribution channels.
We also note that discreet financial inform ation for each business units is prepared and
reviewed by segment managers.  Please e xplain whether the company analyzes the
profitability of each of th e business units and compares it to the other units.  If so, tell us who
is responsible for evaluating the performan ce, how it is done and to whom is this
communicated.

3. We note your response that due to the insigni ficance of the EMEA, La tin America and Asia
operating segments, they were combined into othe r foreign countries for disclosure purposes.
We also note that all non-allocated shared se rvices, which include marketing, administrative,
distribution, and innovation, were  included in the North America operating segment.
Therefore, please discuss the method used to allocate resources to EM EA, Latin America and
Asia operating segments.

4. We note your response that your operating se gments are North America, EMEA, Latin
America and Asia.  Based on the CODM pack age provided specifically the contribution
margin analysis, we note that revenues from  EMEA are 3.3%, Latin America are 0.5% and
Asia are 1.4% of total revenues.   As none of these segments nor the combined other foreign
countries meet the quantitative threshold of 10% in determining operating segments, please
discuss why management believes this inform ation about the international segments is
material and useful to readers of  the financial statements.

5. We note your response that “segment managers are the combination of EVP Product and
EVP Business Development for the North American operating segment and the COO for the EMEA, Latin America and Asia operating segments.”  We also note that the COO also continues his functional administ rative responsibilities. The orga nizational structure does not
appear aligned with how you report segments as you have two segment managers for one
segment (North America) and one segment mana ger for the three international segments.
Please discuss the factors considered by the CODM in allocating hu man resources to the
operating segments.

6. We reviewed the supplemental information provi ded in the two financial packages provided
to the CODM and have the following questions.
 We note that the CODM receives disaggreg ated net revenue by business unit.  In
discussing drivers of revenues, you note info rmation by distribution channel and product
categories.  On page 4 of the Q4 Boar d Presentation you present gross margins by
Apparel, Footwear, E-commer ce and International.  Please discuss whether the CODM

Kevin A. Plank, President  Under Armour, Inc. August 1, 2011 Page 3

 received any financial performance informati on below revenues for any of the periods in
2010.
 We note on page 13 of the Executive Financ ial Review-KP Edition, your CODM receives
an excess inventory analysis by product categories – Appare l and accessories, Footwear
and Europe.  Please discuss how this informa tion is used in allo cating resources.

 We note on page 11 of the Executive Financ ial Review-KP Edition, your CODM receives
an SG&A analysis which separately pres ents expenses by distribution channel and
product categories, US Wholesale and US Di rect to Consumer categories which are
further disaggregated into US Apparel, US  Footwear, eCommerce, Factory House and
Specialty subcategories. We note the inform ation provided in the CODM package that
the CODM receives SGA analysis by product cat egory.  Tell us who makes the decisions
and how selling and product creation dolla rs are allocated fo r each of the product
categories.  Please clarify the CODM’s ro le in determining how SGA expenses are
incurred.

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.
You may contact Brian McAllister at (202)  551-3341 or Nasreen Mohammed at (202)
551-3773 if you have questions regarding comments  on the financial statements and related
matters.  Please contact me at ( 202) 551-3790 with any other questions.

Sincerely,
   /s/Tia Jenkins
    Tia Jenkins

Senior Assistant Chief Accountant
Office of Beverages, Apparel, and
Health care Services