Correspondence 0001104659-23-079847 from SharkNinja, Inc. (SN) (CIK 0001957132) (SN)
SharkNinja, Inc. (SN) (CIK 0001957132)
Date: July 11, 2023 · CIK: 0001957132 · Accession: 0001104659-23-079847
AI Filing Summary & Sentiment
File numbers found in text: 333-272973
Referenced dates: July 3, 2023
Letter
Skadden, Arps, Slate, Meagher & Flom llp
One Manhattan West FIRM/AFFILIATE
New York, NY 10001 OFFICES
________ ----------
TEL: (212) 735-3000 BOSTON
FAX: (212) 735-2000 CHICAGO
www.skadden.com HOUSTON
LOS ANGELES
PALO ALTO
WASHINGTON, D.C.
WILMINGTON
----------
BEIJING
BRUSSELS
FRANKFURT
HONG KONG
LONDON
MUNICH
PARIS
SÃO PAULO
SEOUL
SHANGHAI
SINGAPORE
TOKYO
TORONTO
July 11, 2023
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549-3561
Attn: Bradley Ecker
Martin James
Erin Purnell
Beverly Singleton
Re: SharkNinja Global SPV, Ltd.
Registration Statement on Form F-1
Filed on June 28, 2023
File No. 333-272973
On behalf of our client, SharkNinja, Inc., a Cayman Islands corporation (the “Company”), we hereby provide responses to comments received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by letter dated July 3, 2023 (the “Comment Letter”) with respect to the above-referenced Registration Statement on Form F-1 filed with the Commission on June 28, 2023 (the “Registration Statement”).
Concurrently with the submission of this letter, the Company is filing, through the Commission’s Electronic Data Gathering, Analysis and Retrieval (“EDGAR”) system, an amendment to the Registration Statement (the “Amendment”) in response to the Staff’s comments and to reflect certain other changes.
The headings and paragraph numbers in this letter correspond to those contained in the Comment Letter and, to facilitate the Staff’s review, we have reproduced the text of the Staff’s comments in bold and italics below. All references to page numbers and captions (other than those in the Staff’s comments and unless otherwise stated) correspond to the page numbers and captions in the Amendment.
Securities and Exchange Commission
July 11, 2023
Page 2
General
1. We note the inclusion of several agreements entered into between SharkNinja and JS Global as exhibits to your registration statement. Please describe the material terms of these agreements wherever applicable in your registration statement. Refer to Item 404 of Regulation S-K.
The Company respectfully acknowledges the Staff’s comment and has revised the disclosure starting on page 148 to further describe the material terms of the agreements entered into between SharkNinja and JS Global.
* * * * *
Please contact me at (212) 735-3712 or ryan.dzierniejko@skadden.com if the Staff has any questions or requires additional information.
Very
truly yours,
/s/
Ryan J. Dzierniejko
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filename1.htm
Skadden,
Arps, Slate, Meagher & Flom llp
One
Manhattan West
FIRM/AFFILIATE
New
York, NY 10001
OFFICES
________
----------
TEL:
(212) 735-3000
BOSTON
FAX:
(212) 735-2000
CHICAGO
www.skadden.com
HOUSTON
LOS
ANGELES
PALO
ALTO
WASHINGTON,
D.C.
WILMINGTON
----------
BEIJING
BRUSSELS
FRANKFURT
HONG
KONG
LONDON
MUNICH
PARIS
SÃO
PAULO
SEOUL
SHANGHAI
SINGAPORE
TOKYO
TORONTO
July 11, 2023
VIA EDGAR
Securities
and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549-3561
Attn:
Bradley Ecker
Martin James
Erin Purnell
Beverly Singleton
Re: SharkNinja Global SPV, Ltd.
Registration Statement on Form F-1
Filed on June 28, 2023
File No. 333-272973
On behalf of our client, SharkNinja, Inc.,
a Cayman Islands corporation (the “Company”), we hereby provide responses to comments received from the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) by letter dated July 3,
2023 (the “Comment Letter”) with respect to the above-referenced Registration Statement on Form F-1 filed with
the Commission on June 28, 2023 (the “Registration Statement”).
Concurrently with the submission of this letter,
the Company is filing, through the Commission’s Electronic Data Gathering, Analysis and Retrieval (“EDGAR”)
system, an amendment to the Registration Statement (the “Amendment”) in response to the Staff’s comments and
to reflect certain other changes.
The headings and paragraph numbers in this letter
correspond to those contained in the Comment Letter and, to facilitate the Staff’s review, we have reproduced the text of the Staff’s
comments in bold and italics below. All references to page numbers and captions (other than those in the Staff’s comments
and unless otherwise stated) correspond to the page numbers and captions in the Amendment.
Securities and Exchange Commission
July 11, 2023
Page 2
General
1. We
note the inclusion of several agreements entered into between SharkNinja and JS Global as
exhibits to your registration statement. Please describe the material terms of these agreements
wherever applicable in your registration statement. Refer to Item 404 of Regulation S-K.
The Company respectfully acknowledges the Staff’s
comment and has revised the disclosure starting on page 148 to further describe the material terms of the agreements entered into
between SharkNinja and JS Global.
* * * * *
Please
contact me at (212) 735-3712 or ryan.dzierniejko@skadden.com if the Staff has any questions or requires additional information.
Very
truly yours,
/s/
Ryan J. Dzierniejko
cc: Mark
Barrocas, President, SharkNinja, Inc.
Larry Flynn, Interim Chief Financial Officer and Chief Accounting Officer, SharkNinja, Inc.
Pedro
J. Lopez-Baldrich, Chief Legal Officer, SharkNinja, Inc.
Howard L. Ellin, Skadden, Arps, Slate, Meagher &
Flom LLP
2