SEC Comment Letter 0000000000-23-010901 to Birkenstock Holding plc (BIRK)
Birkenstock Holding plc
Date: Oct. 3, 2023 · CIK: 0001977102 · Accession: 0000000000-23-010901
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Reasoning
File numbers found in text: 333-274483
Letter
United States securities and exchange commission logo October 3, 2023 Oliver Reichert Chief Executive Officer Birkenstock Holding Ltd 1-2 Berkeley Square London W1J 6EA United Kingdom Re:Birkenstock Holding Ltd Amendment No. 2 to Registration Statement on Form F-1 Filed October 2, 2023 File No. 333-274483 Dear Oliver Reichert: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our September 26, 2023 letter. Amendment No. 2 to Registration Statement on Form F-1 filed on October 2, 2023 Capitalization, page 78 1.Revise the adjusted column of the table to remove your cash and cash equivalents of €289,609 from the amount currently presented as ''Total shareholders’ equity and indebtedness". Further, please revise to title the caption "total capitalization".
FirstName LastNameOliver Reichert Comapany NameBirkenstock Holding Ltd October 3, 2023 Page 2 FirstName LastName Oliver Reichert Birkenstock Holding Ltd October 3, 2023 Page 2 Please contact Charles Eastman at 202-551-3794 or Martin James at 202-551-3671 if you have questions regarding comments on the financial statements and related matters. Please contact Erin Donahue at 202-551-6063 or Erin Purnell at 202-551-3454 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Ross Leff
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United States securities and exchange commission logo
October 3, 2023
Oliver Reichert
Chief Executive Officer
Birkenstock Holding Ltd
1-2 Berkeley Square
London W1J 6EA
United Kingdom
Re:Birkenstock Holding Ltd
Amendment No. 2 to Registration Statement on Form F-1
Filed October 2, 2023
File No. 333-274483
Dear Oliver Reichert:
We have reviewed your amended registration statement and have the following comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our September 26, 2023 letter.
Amendment No. 2 to Registration Statement on Form F-1 filed on October 2, 2023
Capitalization, page 78
1.Revise the adjusted column of the table to remove your cash and cash equivalents
of €289,609 from the amount currently presented as ''Total shareholders’ equity and
indebtedness". Further, please revise to title the caption "total capitalization".
FirstName LastNameOliver Reichert
Comapany NameBirkenstock Holding Ltd
October 3, 2023 Page 2
FirstName LastName
Oliver Reichert
Birkenstock Holding Ltd
October 3, 2023
Page 2
Please contact Charles Eastman at 202-551-3794 or Martin James at 202-551-3671 if you
have questions regarding comments on the financial statements and related matters. Please
contact Erin Donahue at 202-551-6063 or Erin Purnell at 202-551-3454 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Ross Leff