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
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CORRESP
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filename1.htm
Skadden,
Arps, Slate, Meagher & Flom llp
One Manhattan
West
FIRM/AFFILIATE
New
York, NY 10001
OFFICES
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TEL:
(212) 735-3000
BOSTON
FAX:
(212) 735-2000
CHICAGO
www.skadden.com
HOUSTON
LOS ANGELES
PALO ALTO
WASHINGTON, D.C.
WILMINGTON
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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
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