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SEC Comment Letter for Under Armour, (UA) — Mar 11, 2026

Under Armour, Inc.
Date: March 11, 2026 · CIK: 0001336917 · Accession: 0000000000-26-002486

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File numbers found in text: 001-33202

Date
March 11, 2026
Author
Division of
Form
UPLOAD
Company
Under Armour, Inc.

Letter

Re: Under Armour, Inc. Form 10-K for the Fiscal Year Ended March 31, 2025 Filed May 22, 2025 File No. 001-33202 Dear Reza Taleghani:

March 11, 2026

Reza Taleghani Chief Financial Officer Under Armour, Inc. 101 Performance Drive Baltimore, Maryland 21230

We have limited our review of your filing to the financial statements and related disclosures and have the following comment.

Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 10-K for the Fiscal Year Ended March 31, 2025 Notes to the Consolidated Financial Statements Note 2. Summary of Significant Accounting Policies Goodwill and Indefinite-Lived Intangible Assets, page 54

1. We note your disclosure that in conducting an annual impairment test, you first review qualitative factors to determine whether it is more likely than not that the fair value of the reporting unit or indefinite-lived intangible asset is less than its carrying amount, and if factors indicate that is the case, or if you choose to bypass the qualitative assessment, you perform a quantitative impairment test. We further note that no goodwill impairments were recorded during Fiscal 2025, Fiscal 2024 or Fiscal 2023. Please revise your disclosures to ensure that you include an accounting policy addressing how you assess goodwill and intangible assets for impairment. Your disclosures should include, but not necessarily be limited to the following: Provide a thorough discussion of your impairment testing policies, including a description of the key assumptions used to estimate the fair value of the reporting units for your goodwill impairment analysis, how the key assumptions were March 11, 2026 Page 2

determined, the degree of uncertainty associated with the key assumptions, and any material changes in the key assumptions during the periods presented. Discuss how goodwill and other intangible assets were tested during the respective periods, including whether you performed a qualitative and/or quantitative test. Indicate how you determine your reporting units for goodwill impairment testing purposes and identify your reporting units. State whether or not the fair values of your reporting units substantially exceed the respective carrying values. To the extent any reporting unit fair values are not substantially in excess of carrying values, disclose the name(s) of the reporting unit(s), the percentage by which the estimated fair value of the reporting unit(s) exceeded the carrying value, the amount of goodwill allocated to the reporting unit(s), and whether the related goodwill is at risk of impairment. Also provide a description of potential events and/or changes in circumstances that could reasonably be expected to negatively affect the key assumptions. Given the revenue decreases in your North America segment, ensure you specifically and comprehensively address the recoverability of respective assets.

In closing, 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.

Please contact Stephany Yang at 202-551-3167 or Melissa Gilmore at 202-551-3777 with any questions.

Sincerely,
Division of
Corporation Finance
Office of
Manufacturing

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 March 11, 2026

Reza Taleghani
Chief Financial Officer
Under Armour, Inc.
101 Performance Drive
Baltimore, Maryland 21230

 Re: Under Armour, Inc.
 Form 10-K for the Fiscal Year Ended March 31, 2025
 Filed May 22, 2025
 File No. 001-33202
Dear Reza Taleghani:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended March 31, 2025
Notes to the Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Goodwill and Indefinite-Lived Intangible Assets, page 54

1. We note your disclosure that in conducting an annual impairment test,
you first
 review qualitative factors to determine whether it is more likely than
not that the fair
 value of the reporting unit or indefinite-lived intangible asset is less
than its carrying
 amount, and if factors indicate that is the case, or if you choose to
bypass the qualitative
 assessment, you perform a quantitative impairment test. We further note
that no goodwill
 impairments were recorded during Fiscal 2025, Fiscal 2024 or Fiscal
2023. Please revise
 your disclosures to ensure that you include an accounting policy
addressing how you
 assess goodwill and intangible assets for impairment. Your disclosures
should include,
 but not necessarily be limited to the following:
 Provide a thorough discussion of your impairment testing policies,
including a
 description of the key assumptions used to estimate the fair value
of the reporting
 units for your goodwill impairment analysis, how the key assumptions
were
 March 11, 2026
Page 2

 determined, the degree of uncertainty associated with the key
assumptions, and any
 material changes in the key assumptions during the periods
presented.
 Discuss how goodwill and other intangible assets were tested
during the respective
 periods, including whether you performed a qualitative and/or
quantitative test.
 Indicate how you determine your reporting units for goodwill
impairment testing
 purposes and identify your reporting units.
 State whether or not the fair values of your reporting units
substantially exceed the
 respective carrying values. To the extent any reporting unit fair
values are not
 substantially in excess of carrying values, disclose the name(s) of
the reporting
 unit(s), the percentage by which the estimated fair value of the
reporting unit(s)
 exceeded the carrying value, the amount of goodwill allocated to the
reporting
 unit(s), and whether the related goodwill is at risk of impairment.
Also provide a
 description of potential events and/or changes in circumstances that
could reasonably
 be expected to negatively affect the key assumptions.
 Given the revenue decreases in your North America segment, ensure
you specifically
 and comprehensively address the recoverability of respective assets.

 In closing, 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.

 Please contact Stephany Yang at 202-551-3167 or Melissa Gilmore at
202-551-3777
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>