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Correspondence 0000950103-25-004569 from Birkenstock Holding plc (BIRK)

Birkenstock Holding plc
Date: April 9, 2025 · CIK: 0001977102 · Accession: 0000950103-25-004569

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File numbers found in text: 001-41836

Referenced dates: MARCH 27, 2025, March 27, 2025

Date
September 30, 2024
Author
/s/
Form
CORRESP
Company
Birkenstock Holding plc

Letter

Via EDGAR Securities and Exchange Commission Division of Corporation Finance - Office of Manufacturing Attention: Ms. Melissa Gilmore and Mr. Kevin Woody Re: Birkenstock Holding plc Form 20-F for the Fiscal Year Ended September 30, 2024 File No. 001-41836 – REQUEST FOR EXTENSION OF TIME TO RESPOND TO COMMENT LETTER DATED MARCH 27, 2025 –

Dear Ms. Gilmore and Mr. Woody:

We are writing in response to the letter of the staff of the Division of Corporation Finance (the "Staff") of the Securities and Exchange Commission to Birkenstock Holding plc ("we," "us," "our," or the "Company"), dated March 27, 2025, in which the Staff requested certain information regarding our Form 20-F filing for the fiscal year ended September 30, 2024. As discussed via E-mail with Ms. Gilmore, we would like to request an extension to the filing deadline for our response as the Company needs more time to gather information and prepare its responses. Currently, a response was requested by the Staff within 10 business days. We respectfully request the Staff to grant an extension of such time and allow the Company to respond to the Staff's letter dated March 27, 2025 by April 16, 2025.

Thank you for your consideration of our request for an extension. If you have any further questions, please feel free to contact our counsel, Leo Borchardt, Esq., of Davis Polk & Wardwell London LLP, at +44-20-7418-1334 or by email at leo.borchardt@davispolk.com.

Sincerely,
/s/
Ivica Krolo

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CORRESP
 1
 filename1.htm

 Birkenstock Holding PLC • 1-2 Berkeley Square • London W1J 6EA • U.K.

 Birkenstock
 Holding PLC
 1-2
 Berkeley Square
 London
 W1J
 6EA
 U.K.

 April 9,
2025

 Via
EDGAR

 Securities
and Exchange Commission

 Division
of Corporation Finance - Office of Manufacturing

 100 F Street,
NE

 Washington,
D.C. 20549

 Attention:
Ms. Melissa Gilmore and Mr. Kevin Woody

 Re:
 Birkenstock Holding plc

 Form 20-F for the Fiscal Year Ended September 30, 2024

 File No. 001-41836

 – REQUEST FOR EXTENSION OF TIME TO RESPOND TO
COMMENT LETTER DATED MARCH 27, 2025 –

 Dear Ms.
Gilmore and Mr. Woody:

 We are writing
in response to the letter of the staff of the Division of Corporation Finance (the "Staff") of the Securities and Exchange
Commission to Birkenstock Holding plc ("we," "us," "our," or the "Company"), dated March
27, 2025, in which the Staff requested certain information regarding our Form 20-F filing for the fiscal year ended September 30, 2024.
As discussed via E-mail with Ms. Gilmore, we would like to request an extension to the filing deadline for our response as the Company
needs more time to gather information and prepare its responses. Currently, a response was requested by the Staff within 10 business
days. We respectfully request the Staff to grant an extension of such time and allow the Company to respond to the Staff's letter
dated March 27, 2025 by April 16, 2025.

 Thank you
for your consideration of our request for an extension. If you have any further questions, please feel free to contact our counsel, Leo
Borchardt, Esq., of Davis Polk & Wardwell London LLP, at +44-20-7418-1334 or by email at leo.borchardt@davispolk.com.

 Sincerely,

 /s/
Ivica Krolo

 Ivica Krolo

 Chief Financial Officer

 (principal financial officer)