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April 28, 2023
Paul Carbone
Chief Financial Officer
SharkNinja Global SPV, Ltd.
89 A Street, #100
Needham, MA 02494
Re:SharkNinja Global SPV, Ltd.
Draft Registration Statement on Form F-1
Submitted April 7, 2023
CIK No. 0001957132
Dear Paul Carbone:
            We have reviewed your amended draft registration statement 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 by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted April 7, 2023
Corporation Information, page 15
1.Please disclose the relationship between JS Holdings Limited Partnership, which is
controlled by Mr. Xuning Wang, and that of JS Global Lifestyle Company Limited, the
parent company of SharkNinja, Inc.  Disclose the relevant ownership or controlling
percentage that Mr. Wang has in these entities.  Please also include organization charts of
the Company before and after the separation and distribution from JS Global, including
detailing the more significant intermediary and subsidiary entities of the Company and its
relationship with the Parent.
2.Wherever applicable, please expand to better explain how it was determined that
separating SharkNinjas's business from JS Global’s current business operations would be

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April 28, 2023
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in the best interests of both entities. Discuss how the separation will lead to the better
focus of each company’s specific operational and growth strategies. Noting your
references to JS Global's "broader corporate organization" on page 52 and that you intend
to continue to enter into various supply agreements with JS Global on page 24, please
provide more information as to JS Global's retained business. Explain in detail the
decision to separate now as opposed to any other time and the reasons underlying the
chosen timing.
Dividend Policy, page 66
3.In the second paragraph please disclose the expected amount, or range thereof, of the
special cash dividend to be paid to JS Global in connection with the separation,
including how you have determined the amount to be paid.
Capitalization, page 67
4.Please expand the table to also include line items for the amount of your short and long-
term debt as shown in the balance sheet on page F-4.  Refer to Item 3.B of the Form 20-F.
5.We note that you present a caption for preferred shares. Please revise the introductory
paragraphs or include a footnote to briefly describe the event or transactions that will
result in your having preferred shares authorized, issued or outstanding on a pro forma
basis. The comment also applies to the Unaudited Pro Forma Condensed Consolidated
Financial Information section.
Unaudited Pro Forma Condensed Consolidated Financial Information, page 69
6.We note your business operations are currently wholly-owned by JS Global. Please
expand the disclosure in the fourth paragraph on page 69 to discuss whether or not there
are any Autonomous Entity adjustments pertaining to incremental costs of being a
separate stand-alone entity, and if so, revise the pro forma financial statements to present
these in a separate column from those of the Transaction Accounting Adjustments.  To the
extent the incremental costs also include items currently described in footnotes 3(f) and
3(g), please identify them as Autonomous Entity Adjustments. Refer to Rule 11-
02(a)(6)(ii) of Regulation S-X.
Unaudited Pro Forma Condensed Consolidated Balance Sheet, page 70
7.Please revise your pro forma balance sheet to show the number of shares authorized,
issued and outstanding on both a historical and pro forma basis.
8.Refer to Note 2(c) on page 73, where you indicate, parenthetically, that both the 2021
Employee Notes and 2022 Employee Notes are defined below.  However, we note no
discussion of these employee notes in the pro forma financial statements.  Please revise
the section to include a description of the 2021 and 2022 Employee Notes, including the
amounts originally issued and the balance outstanding as of the most recent balance sheet

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April 28, 2023
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date. Alternatively, revise Note 2(c) to cross-reference to the appropriate pages of the
filing where the information is disclosed.
Unaudited Pro Forma Condensed Consolidated Statements of Income, page 71
9.We note from the Dividend Policy section on page 66, that in February 2023 you paid
special cash dividends of $15.5 million and $99 million to JS Global, and that you expect
to pay a special cash dividend to JS Global in connection with the separation and
distribution.  Please revise the pro forma balance sheet to give pro forma effect to these
distributions. Refer to SAB Topic 1.B.3. The comment also applies to your capitalization
table.
10.We note disclosure on page F-30 that your employees participate in JS Global's restricted
share units plan, pursuant to which ordinary shares of JS Global underlying the restricted
share units, or RSUs, are transferred to them upon vesting.  Please explain to us how the
separation and distribution will impact the RSUs, including any changes in the timing and
terms of vesting as well as whether grantees will still be entitled to receive ordinary shares
of JS Global or ordinary shares of the registrant instead.  Tell us how you intend
to account for any such changes and your consideration of disclosing these changes in the
pro forma financial statements.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 84
11.Refer to footnote (6) to the reconciliation of Adjusted Net Income that begins at the
bottom on page 86. Please explain to us in detail your reasons for adjusting for
the amortization of acquired intangible assets when calculating non-GAAP net income.
Discuss in more detail why the amortization of revenue generating intangible assets
currently reflected on your balance sheet would not be considered normal recurring
operating expenses "because they relate to JS Global’s acquisition of your
business." Refer to Question No. 100.01 of the Staff's Compliance & Disclosure
Interpretations on Non-GAAP Financial Measures, as updated December 13, 2022.
12.We note the disclosure in footnote (2) on page 19. Please clearly describe to us in more
detail the reasons for recording the Product Procurement Adjustment when presenting
your non-GAAP measures. Describe to us the transaction that resulted in the inventory
markups in your cost of sales and explain why they will be eliminated as a result of the
separation.
Liquidity and Capital Resources
Indebtedness, page 89
13.Refer to the second paragraph.  Please revise to disclose the amount of any borrowings
and repayments under the Revolving Facility during the periods presented as well as the
outstanding and available balances as of the date of each balance sheet.  With regards to
your LIBOR based debt, please discuss the impact on your financial statements and your

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April 28, 2023
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liquidity position as a result of the planned transition away from LIBOR by end of June
2023. Discuss your plans with respect to the use of an alternative reference rate.  Please
also include a Risk Factor as to the transition away from LIBOR.  For guidance, refer to
our Joint Staff Statement on LIBOR Transition, issued July 12, 2019, and our Staff
Statement on LIBOR Transition - Key Considerations for Market Participants, issued
December 7, 2021.
Critical Accounting Policies and Estimates
Goodwill and Intangible Assets, page 92
14.We note that your goodwill has been assigned to your one reporting unit, and that your
policy includes testing goodwill annually and performing a qualitative assessment and, if
further necessary, a quantitative impairment test. Please revise to disclose the date on
which you perform your annual impairment testing of both goodwill and indefinite-lived
intangible assets and identify any reported period in which you performed a quantitative
impairment test. For both goodwill and indefinite-lived intangible assets, disclose the
outcome of your qualitative assessment in each annual period reported and, as applicable,
the results of any quantitative tests performed.  Also, consider disclosing the dollar
amount or percentage range by which the fair value from your quantitative impairment
test of goodwill exceeded its carrying value. Refer to ASC 350-20-35-3 and 35-3E.
Manufacturing, Supply Chain & Logistics, page 119
15.Please expand your disclosure in this section to describe the relationship you have with
your manufacturing partners, including where they are based, manufacturing capacities,
company oversight, and any existing long-term manufacturing contracts which you are
substantially dependent upon. Additionally, disclose the extent to which you manufacture
your own products.
BUSINESS
Facilities, page 124
16.We note your disclosure that "as of December 31, 2022, [you] leased facilities totaling
approximately 1,327,000 square feet in multiple locations in the United States and
internationally." Please revise to disclose the utilization of your leased facilities. Refer to
Item 4.D. of Form 20-F.
Management, page 125
17.We note that Mark Barrocas has served as Global President of JS Global since 2019.
Please disclose whether Mr. Barrocas will continue to serve in this role after the
Separation.

 FirstName LastNamePaul Carbone
 Comapany NameSharkNinja Global SPV, Ltd.
 April 28, 2023 Page 5
 FirstName LastName
Paul Carbone
SharkNinja Global SPV, Ltd.
April 28, 2023
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Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page F-16
18.Refer to disaggregation of net sales that begin on page F-18.  Please tell us the
consideration given to further disaggregating your net sales by sales channel.  In this
regard, we note disclosure on page 75 that you sell your products using an omnichannel
distribution strategy that consists primarily of retail and direct-to-consumer (DTC)
channels.  Also, as disclosed on page F-16, your customers primarily consist of retailers,
distributors and DTC customers.  Refer to ASC 606-10-55-91(g).
Index to Exhibits, page II-3
19.You reference various distribution, separation, transition and supplier agreements
throughout the prospectus. Please file them as exhibits.
General
20.Please provide us with supplemental copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
have presented or expect to present to potential investors, whether or not you retained, or
intend to retain, copies of those communications.
            You may contact Beverly Singleton at 202-551-3328 or Martin James at 202-551-3671 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Bradley Ecker at 202-551-4985 or Erin Purnell at 202-551-3454 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing