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Correspondence

 August 26, 2011

 VIA EDGAR

 Mr. John Reynolds

 Assistant Director

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street,
N.E.

 Washington, D.C. 20549

Re:
Under Armour, Inc.

Form 10-K for Fiscal Year End December 31, 2010

 Filed February 24, 2011

 File No. 001-33202

Dear Mr. Reynolds:

 Under
Armour, Inc. (“we”, “our”, “UA” or the “Company”) is responding to the comments of the Staff of the Securities and Exchange Commission (the “Commission”) in its letter dated August 1, 2011. To
assist in your review, we have included the Staff’s comments below prior to our responses.

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

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

Comment 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 change between periods, please quantify the extent to which each reason contributed to the overall
change. See Item 303(A)(3) of Regulation SK.

 Response

 We believe we have addressed the Staff’s comment in our Form 10-Q for the quarterly period ending June 30, 2011 filed with the SEC on August 4, 2011 (“second quarter Form 10-Q”).
In response to this comment, we provided additional disclosure in our Management’s Discussion & Analysis (“MD&A”) of the reasons for changes in the operating results of each of our segments, and, consistent with
Regulation S-K Item 303(A)(3), we discussed items that materially affected the operating results and we will continue to provide such disclosure in our future filings.

 Securities and Exchange Commission

 August 26, 2011

  Page
 2

 Below is an excerpt from our second quarter Form 10-Q. This discussion was included as a new section
titled “Segment Results of Operations” included at the end of the Consolidated Results of Operations sections.

 Segment Results
of Operations

 Three Months Ended June 30, 2011 Compared to Three Months Ended June 30, 2010

Net revenues by geographic region are summarized below:

Three Months Ended June 30,

 (In thousands)

2011

2010

$ Change

% Change

 North America

$
277,442

$
196,008

$
81,434

41.5
%

 Other foreign countries

13,894

8,778

5,116

58.3

 Total net revenues

$
291,336

$
204,786

$
86,550

42.3
%

 Net revenues in North America increased $81.4 million to $277.4 million for the three months ended
June 30, 2011 from $196.0 million for the same period in 2010 primarily due to the items discussed above in the Consolidated Results of Operations. Net revenues in other foreign countries increased by $5.1 million to $13.9 million for the three
months ended June 30, 2011 from $8.8 million for the same period in 2010 primarily due to increased unit sales in our Europe, Middle East and Africa (“EMEA”) operating segment as well as unit sales growth to our distributors in our
Asia and Latin America operating segments, partially offset by decreased product distribution and associated license revenues by our licensee in Japan due to the recent earthquake and tsunami.

Operating income (loss) by geographic region is summarized below:

Three Months Ended June 30,

 (In thousands)

2011

2010

$ Change

% Change

 North America

$
12,656

$
6,211

$
6,445

103.8
%

 Other foreign countries

(1,298
)

681

(1,979
)

(290.6
)

 Total operating income

$
11,358

$
6,892

$
4,466

64.8
%

 Operating income in North America increased $6.5 million to $12.7 million for the three months ended
June 30, 2011 from $6.2 million for the same period in 2010 primarily due to the items discussed above in the Consolidated Results of Operations. Operating loss in other foreign countries was $1.3 million, a decrease of $2.0 million, for the
three months ended June 30, 2011 from operating income of $0.7 million for the same period in 2010 primarily due to decreased product distribution and associated higher margin license revenues by our licensee in Japan due to the recent
earthquake and tsunami and increased costs associated with our continued investment to support our international expansion in Asia and Latin America.

 Securities and Exchange Commission

 August 26, 2011

  Page
 3

 Six Months Ended June 30, 2011 Compared to Six Months Ended June 30, 2010

Net revenues by geographic region are summarized below:

Six Months Ended June 30,

 (In thousands)

2011

2010

$ Change

% Change

 North America

$
573,519

$
411,766

$
161,753

39.3
%

 Other foreign countries

30,516

22,427

8,089

36.1

 Total net revenues

$
604,035

$
434,193

$
169,842

39.1
%

 Net revenues in North America increased $161.7 million to $573.5 million for the six months ended
June 30, 2011 from $411.8 million for the same period in 2010 primarily due to the items discussed above in the Consolidated Results of Operations. Net revenues in other foreign countries increased by $8.1 million to $30.5 million for the six
months ended June 30, 2011 from $22.4 million for the same period in 2010 primarily due to unit sales growth in our EMEA operating segment as well as unit sales growth to our distributors in our Asia and Latin America operating segments.

 Operating income by geographic region is summarized below:

Six Months Ended June 30,

 (In thousands)

2011

2010

$ Change

% Change

 North America

$
31,211

$
18,974

$
12,237

64.5
%

 Other foreign countries

1,289

1,502

(213
)

(14.2
)

 Total operating income

$
32,500

$
20,476

$
12,024

58.7
%

 Operating income in North America increased $12.2 million to $31.2 million for the six months ended
June 30, 2011 from $19.0 million for the same period in 2010 primarily due to the items discussed above in the Consolidated Results of Operations. Operating income in other foreign countries decreased by $0.2 million to $1.3 million for the six
months ended June 30, 2011 from $1.5 million for the same period in 2010 primarily due to increased costs related to our continued investment to support our international expansion in Asia and Latin America, partially offset by increased unit
sales growth by our distributors in our Asia and EMEA operating segments and increased product distribution and associated higher margin license revenues by our licensee in Japan.

 Notes to Consolidated Financial Statements, page 49

 16. Segment Data and related
Information, page 67

Comment 2.
We note your response to prior comment four in our letter dated May 4, 2011 stating that you have ten business units which are a mix of geographies, products
and distribution channels. We also note that discreet financial information for each business units is prepared and reviewed by segment managers. Please explain whether the company analyzes the profitability of each of the business units and
compares it to the other units. If so, tell us who is responsible for evaluating the performance, how it is done and to whom is this communicated.

 Securities and Exchange Commission

 August 26, 2011

  Page
 4

 Response

 As previously discussed, discrete financial information, including revenue, profit margin and operating income, is available by business unit and is used by the segment managers and various personnel
within the business units. The Chief Operating Officer (“COO”), Executive Vice President Product (“EVP Product”), and Executive Vice President Business Development (“EVP Business Development”) (collectively the
“segment managers”) and the Chief Financial Officer (“CFO”), review the available discrete financial information and compare the information to the current version of the respective business unit’s forecast. The performance
of the business units is primarily assessed on this review. The Company does not perform comparative profitability analysis between the business units.

 As previously noted, UA’s Chief Executive Officer (“CEO”) is UA’s chief operating decision maker (“CODM”). The CODM assists in establishing the consolidated net revenue and
operating income targets for incentive plans and forecasts. The segment managers, in coordination with the CFO, develop plans with the business unit managers to achieve these consolidated targets. Each segment manager maintains periodic contact with
the CODM to discuss and report on operating activities and plans for their respective operating segment, including the activities of the business units within the segment. However, the CODM regularly reviews consolidated and geographic segment
financial data to make decisions about resources to be allocated to the segment and assess its performance.

Comment 3.
We note your response that due to the insignificance of the EMEA, Latin America and Asia operating segments, they were combined into other foreign countries for
disclosure purposes. We also note that all non-allocated shared services, which include marketing, administrative, distribution, and innovation, were included in the North American operating segment. Therefore, please discuss the method used to
allocate resources to EMEA, Latin America and Asia operating segments.

 Response

The EMEA, Latin American and Asian operating segments include directly attributable costs related to the activities of these segments. For example, the
EMEA operating segment includes marketing, administrative and distribution expenses specific to this operating segment such as regional sponsorships or the operating costs for the local distribution facility. The Latin American and Asian operating
segments include distributor and license revenues. For these two operating segments, a third party controls the activities and incurs the costs to market and distribute to third party retailers in the foreign location, and thus the Company’s
marketing, administrative, distribution and product innovation costs are minimal. The Company does not allocate any other marketing, administrative, distribution and product innovation costs to these segments. Substantially all of these remaining
costs were incurred by the North American operating segment, and thus these costs are included with the North American operating segment.

 Securities and Exchange Commission

 August 26, 2011

  Page
 5

Comment 4.
We note your response that your operating segments are North America, EMEA, Latin America and Asia. Based on the CODM package 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 information about the international segments is material and useful to readers of the financial statements.

 Response

 As previously discussed, beginning with the second quarter of 2010, our CODM
regularly reviews financial and operating information organized into four geographically-based operating segments due to the continued global growth and expected global expansion of the Company. In accordance with the quantitative thresholds set
forth in ASC 280-10-50-12 and ASC 280-10-50-14, the Company began separately reporting information about our North American operating segment (effective with our Form 10-Q for the quarterly period ending June 30, 2010). In addition, in
accordance with ASC 280-10-50-15 we have combined the information about the EMEA, Latin American and Asian operating segments in an “all other” category. One of our key strategic objectives is to be a global brand, and we expect the
foreign operating segments to meet the quantitative thresholds in the future. Therefore, we view these operating segments as key long-term growth components of our business. We believe this presentation is relevant to our financial statement readers
as it will exhibit the execution of our long-term growth initiatives, as well as facilitate comparisons to our competitors.

Comment 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 administrative responsibilities. The organizational structure does not appear aligned with how you report segments as you have
two segment managers for one segment (North America) and one segment manager for the three international segments. Please discuss the factors considered by the CODM in allocating human resources to the operating segments.

 Response

As previously discussed, the long term structure includes a segment manager that would be responsible for the North American operating segment, and from
July 2008 to August 2010 the Company had a President with responsibility for what is currently the North America operating segment. Since the North American segment manager’s departure, the CODM has assigned joint responsibility for the North
American operating segment to the EVP Product and EVP Business Development on an interim basis.

 Securities and Exchange Commission

 August 26, 2011

  Page
 6

 Although currently the EMEA, Latin American and Asian operating segments are quantitatively
insignificant, they represent key opportunities in the Company’s long-term growth strategy. Given the size and scope of these operating segments currently, we believe that in the interim they can be effectively managed by one individual.
Currently, the Latin American and Asian operating segments are distributor and licensing models under which a third party controls the activities and incurs the costs to market and to distribute to third party retailers in the foreign locations. As
such these segments require less dedicated management oversight, and thus the CODM has determined that separate segment managers reporting to the CODM are unnecessary. According to ASC 280-10-50-8, a single manager may be the segment manager for
more than one operating segment. As the Company continues to expand globally, it expects that each major geographic region will be structured like the North American operating segment and will have a leader and business units by product and
distribution. Management believes international expansion provides significant long term growth opportunities for the Company, which is in line with our focus on geographic segments.

Comment 6.
We reviewed the supplemental information provided in the two financial packages provided to the CODM and have the following questions.

•

 We note that the CODM receives disaggregated net revenue by business unit. In discussing drivers of revenues, you note information by
distribution channel and product categories. On page 4 of the Q4 Board Presentation you present gross margins by Apparel, Footwear, E-commerce and International. Please discuss whether the CODM received any financial performance information below
revenues for any of the periods in 2010.

•

 We note on page 13 of the Executive Financial Review-KP Edition, your CODM receives an excess inventory analysis by product categories –
Apparel and accessories, Footwear and Europe. Please discuss how this information is used in allocating resources.

•

 We note on page 11 of the Executive Financial Review-KP Edition, your CODM receives an SG&A analysis which separately presents expenses
by distribution channel and product categories, US Wholesale and US Direct to Consumer categories which are further disaggregated into US Apparel, US Footwear, eCommerce, Factory House and Specialty subcategories. We note the information provided in
the CODM package that the CODM receives SGA analysis by product category. Tell us who makes the decisions and how selling and product creation dollars are allocat