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March 14, 2023
Andrew Keegan
Interim Chief Financial Officer
Vista Outdoor Inc.
1 Vista Way
Anoka, MN 55303
Re:Vista Outdoor Inc.
Form 10-K for the Fiscal Year Ended March 31, 2022
Filed May 24, 2022
Form 8-K Filed February 2, 2023
File No. 001-36597
Dear Andrew Keegan:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended March 31, 2022
Consolidated Statements of Comprehensive Income (Loss), page 41
1.We note that you present the line item “earnings (loss) before interest and income taxes,”
or EBIT, on the face of your consolidated statements of comprehensive income. Please tell
us how this presentation complies with Item 10(e)(1)(ii)(C) of Regulation S-K.
Form 8-K filed February 2, 2023
Exhibit 99.1
General, page 1
2.We refer to your presentation of the non-GAAP measures EBITDA Margin and Free Cash
Flow in the secondary headline, as well as the discussion and analysis of EBITDA in the
body of your earnings release. In future filings, please revise your disclosures to also

 FirstName LastNameAndrew Keegan
 Comapany NameVista Outdoor Inc.
 March 14, 2023 Page 2
 FirstName LastName
Andrew Keegan
Vista Outdoor Inc.
March 14, 2023
Page 2
present, with equal or greater prominence, the most directly comparable financial
measures calculated in accordance with GAAP. Refer to Item 10(e)(1)(i)(A) of Regulation
S-K and Question 102.10(a) of the SEC's Compliance and Disclosure Interpretations on
Non-GAAP Financial Measures.
Free Cash Flows, page 6
3.We note you present a measure described as "free cash flow."  It is unclear what
information your measure is attempting to convey, as it appears to conflate elements of
both liquidity and performance measures.  Generally, free cash flow is understood to be a
liquidity measure and is presented as cash flows from operating activities, less capital
expenditures.  At a minimum, it appears you should revise the description of your measure
to something other than "free cash flow."  In addition, your disclosure states the measure
provides investors with information regarding cash available for debt payments, share
repurchases and acquisitions.  It's unclear how adjustments such as amounts paid for
separation costs, transaction costs, etc., are available for purposes such as debt payments.
Further, it is unclear why you are also tax effecting your adjustments, if your measure is
intended to be a liquidity measure.  Please explain the basis for your measure and why you
believe it is appropriate or revise the measure accordingly.
            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.
            You may contact Dale Welcome at 202-551-3865 or Kevin Stertzel at 202-551-3723 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing