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 December 15, 2025

Dennis Schemm
Chief Financial Officer
Fox Factory Holding Corp
2055 Sugarloaf Circle, Suite 300
Duluth, GA 30097

 Re: Fox Factory Holding Corp
 Form 10-K for the Year Ended January 3, 2025
 Form 8-K furnished August 7, 2025
 File No. 001-36040
Dear Dennis Schemm:

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

 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 January 3, 2025
Segment Review, page 51

1. We note your disclosure of an Adjusted EBITDA measure which is
calculated as the
 sum of the segment Adjusted EBITDA measures less unallocated corporate
expenses.
 Please note that the total of any segment profitability measures outside
the required
 ASC 280 disclosure in the notes to the financial statements represents a
non-GAAP
 financial measure and should be accompanied by appropriate disclosure
under Item
 10(e) of Regulation S-K. In addition, the measure must comply with our
guidance on
 Non-GAAP financial measures which includes the prohibition on excluding
normal
 recurring operating expenses from a Non-GAAP profitability measure. See
Question
 100.01 of the SEC Staff s Compliance & Disclosure Interpretations on
Non-GAAP
 Financial Measures. Please revise accordingly.
 December 15, 2025
Page 2

Note 1. Description of the Business, Basis of Presentation and Summary of
Significant
Accounting Policies
Non-GAAP Financial Measures, page 86

2. We note your disclosure in Note 1 of a Non-GAAP Financial Measure titled
Total
 Adjusted EBITDA which appears to relate to the consolidated, or total
Adjusted
 EBITDA measure disclosed in your segment disclosure in Note 20. Please
note that
 presentation of a total or consolidated Adjusted EBITDA amount, other
than in the
 reconciliation of the sum of the reportable segments Adjusted EBTIDA
measures to
 your consolidated income before taxes, would be the presentation of a
non-GAAP
 financial measure that is not permitted in the notes to the financial
statements under
 Item 10(e)(ii)(C). In this regard, we note that ASC 280-10-50-28A allows
for
 disclosure of a second segment profitability measure even if considered
non-GAAP,
 however it must be a measure of segment profitability and not a
consolidated
 measure. As discussed in the comment on Note 20 below, the measure of
total
 Adjusted EBITDA is not consistent with the guidance in ASC 280 and it
would not be
 allowed in the notes to the financial statements. Please revise your
disclosure in Note
 20 and removed the disclosure in Note 1 referring to this Total Adjusted
EBITDA
 measure.
Note 20. Segment Information, page 112

3. We note your disclosure in Note 20 of each segment s profitability
measure of
 Adjusted EBITDA. We further note that you disclose a total for these
amounts less
 unallocated corporate expenses to arrive at a total Adjusted EBITDA
amount. This
 amount is reconciled to net income immediately prior to the disclosure.
Please note
 that ASC 280-10-50-30(b) requires a reconciliation which begins with the
total of the
 reportable segment profitability measures and reconciles to your
consolidated income
 before income taxes and discontinued operations. In providing this
reconciliation,
 unallocated corporate expenses would be considered a reconciling item
below the
 total of segment Adjusted EBITDA. Please revise your reconciliation
accordingly.
 See example of a reconciliation in ASC 280-10-55-48.
4. We note that on page 114 you disclose the other segment items for each
of your three
 reportable segments and include a line for unallocated corporate
expenses to arrive at
 a total for these amounts. Please note that presentation of this total
is not consistent
 with the guidance in ASC 280 and should be removed as it represents a
non-GAAP
 financial measure. Additionally, we note that you do not present
significant segment
 expenses in your disclosure and instead disclose that individual
expenses are not a
 primary focus in segment-level decision-making as the CODM relies on
adjusted
 EBITDA as the key financial metric for assessing performance and
allocating
 resources across segments. Please revise to include disclosure of the
nature of the
 expense information the chief operating decision maker uses to manage
operations as
 required by ASC 280-10-50-26C.
 December 15, 2025
Page 3

 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 Claire Erlanger at 202-551-3301 or Kevin Woody at
202-551-3629
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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