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Correspondence 0001104659-23-082731 from SharkNinja, Inc. (SN) (CIK 0001957132) (SN)

SharkNinja, Inc. (SN) (CIK 0001957132)
Date: July 20, 2023 · CIK: 0001957132 · Accession: 0001104659-23-082731

AI Filing Summary & Sentiment

File numbers found in text: 333-272973

Referenced dates: July 18, 2023

Date
July 20, 2023
Author
/s/ Ryan J. Dzierniejko
Form
CORRESP
Company
SharkNinja, Inc. (SN) (CIK 0001957132)

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 20, 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.

Amendment No. 1 to Registration Statement on Form F-1

Filed on July 11, 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 18, 2023 (the “Comment Letter”) with respect to the above-referenced Amendment No. 1 to Registration Statement on Form F-1 filed with the Commission on July 11, 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 20, 2023

Page 2

General

1. Please file a pre-effective amendment to the registration statement that includes the total number of ordinary shares that you are registering on the cover page. Please also state on the cover page that each JS Global Shareholder as of the Record Date will be entitled to receive one of your ordinary shares for every 25 ordinary shares of JS Global held by such shareholder.

The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on the cover page to include the total number of ordinary shares that the Company is registering and state that each JS Global Shareholder as of the Record Date will be entitled to receive one ordinary share for every 25 ordinary shares of JS Global held by such shareholder.

* * * * *

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

Show Raw Text
CORRESP
1
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 20, 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.

    Amendment No. 1 to Registration Statement on Form F-1

    Filed on July 11, 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 18, 2023 (the “Comment Letter”)
with respect to the above-referenced Amendment No. 1 to Registration Statement on Form F-1 filed with the Commission on July 11, 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 20, 2023

Page 2

General

 1. Please file a pre-effective amendment to the registration statement that includes the total number of ordinary shares that you
are registering on the cover page. Please also state on the cover page that each JS Global Shareholder as of the Record Date will be entitled
to receive one of your ordinary shares for every 25 ordinary shares of JS Global held by such shareholder.

The Company respectfully acknowledges the Staff’s
comment and has revised the disclosure on the cover page to include the total number of ordinary shares that the Company is registering
and state that each JS Global Shareholder as of the Record Date will be entitled to receive one ordinary share for every 25 ordinary shares
of JS Global held by such shareholder.

* * * * *

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