SecProbe.io

December 14, 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 Ended December 31, 2010 Filed February 24, 2011 Correspondence submitted November 14, 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

 1. We note your response to prior comments stati ng that the key performance metrics used
by your CODM to assess performance and allo cate resources are revenues, gross margin,
contribution margin and inve ntory.  Please confirm to us , if true, that the CODM:
 • Does not receive key performance metrics reports on any of the Company's Business
Units, orally, online, in print, or otherwis e directly or indirectly, from the Business
Unit Leaders or from other corporate offi cers, including but not limited to the Chief
Operating Officer, and Executive Vice Presid ents (collectively “Segment Managers”),
Chief Financial Officer or their respective staff.

•
Neither assesses performance of nor approve s allocations of corporate resources to
Business Units, but, instead, defers to the Chief Financial Officer, Segment

Kevin A. Plank Under Armour, Inc. December 14, 2011 Page 2

 Managers, or others for these functions.
  2. We note your response to prior comment five  and general disclosure in Management
Discussion and Analysis in your 10-K on the gross profit margin relationship of your
footwear and apparel product ca tegories.  We also note that  your gross profit decreased
by 2.5% and 2% during the three and nine months ended September 30, 2011 due to
variability in product mix, input costs and other factors.  Additionally, we note diverging growth trends in your produc t categories.  To help investors gain a more thorough
understanding of your earnings, tr ends in profitability, and potential variability, please
provide a more robust discussion that include s the gross profit percentages or amounts
associated with each of your product categorie s for each period presented.  Please also
discuss historical trends, fact ors causing them, and your consid eration as to whether those
trends are likely to continue.  If you are una ble to assess whether tr ends are likely to
continue, please disclose the reasons why.  Please provide us with the text of your
proposed disclosure based on your September 30, 2011 results that you plan to include in
future filings.  Please see SEC Release 33-8350 for guidance.    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) 551-3871 with any other questions.

Sincerely,
   /s/Tia L. Jenkins
    Tia L. Jenkins

Senior Assistant Chief Accountant
Office of Beverages, Apparel, and
Mining