SEC Comment Letter 0000000000-24-001005 to Amer Sports, Inc. (AS)
Amer Sports, Inc.
Date: Jan. 25, 2024 · CIK: 0001988894 · Accession: 0000000000-24-001005
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-276370
Letter
United States securities and exchange commission logo January 25, 2024 Andrew Page Chief Financial Officer Amer Sports, Inc. Cricket Square, Hutchins Drive P.O. Box 2681 Grand Cayman, KY1-1111 Cayman Islands Re:Amer Sports, Inc. Amendment No. 1 to Registration Statement on Form F-1 Filed January 22, 2024 File No. 333-276370 Dear Andrew Page: We have reviewed your amended registration statement and have the following comments. 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 January 18, 2024 letter. Form F-1/A Capitalization, page 81 1.We note the significant increase in accumulated (deficit)/profit between the "actual" and "as adjusted" columns of your capitalization table. We further note from your statements of changes in shareholders' equity (deficit) on pages F-6 and F-31 that the accumulated deficit balance includes not only net losses for the period but also capital contributions and components of other comprehensive income, including foreign currency translation. Please tell us how your aggregation of these amounts within the accumulated deficit balance complies with IAS 1, particularly paragraphs 78(e), 106, and 108. Also clearly disclose the adjustments to each individual equity line item within the footnotes to your capitalization table.
FirstName LastNameAndrew Page Comapany NameAmer Sports, Inc. January 25, 2024 Page 2 FirstName LastName Andrew Page Amer Sports, Inc. January 25, 2024 Page 2 General 2.Please identify the parties that indicated interest in purchasing shares in the IPO and ensure that your disclosure on this topic is consistent throughout the prospectus. For example, on the cover, you indicate that entities "affiliated with" Anta Sports, Anamered, and Tencent, have indicated an interest in purchasing shares in the IPO but elsewhere, such as on page 17, you disclose that ANTA Sports, Anamered and Tencent have indicated interest. Please contact SiSi Cheng at 202-551-5004 or Andrew Blume at 202-551-3254 if you have questions regarding comments on the financial statements and related matters. Please contact Bradley Ecker at 202-551-4985 or Jay Ingram at 202-551-3397 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
January 25, 2024
Andrew Page
Chief Financial Officer
Amer Sports, Inc.
Cricket Square, Hutchins Drive
P.O. Box 2681
Grand Cayman, KY1-1111
Cayman Islands
Re:Amer Sports, Inc.
Amendment No. 1 to Registration Statement on Form F-1
Filed January 22, 2024
File No. 333-276370
Dear Andrew Page:
We have reviewed your amended registration statement and have the following
comments.
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 January 18, 2024 letter.
Form F-1/A
Capitalization, page 81
1.We note the significant increase in accumulated (deficit)/profit between the "actual" and
"as adjusted" columns of your capitalization table. We further note from your statements
of changes in shareholders' equity (deficit) on pages F-6 and F-31 that the accumulated
deficit balance includes not only net losses for the period but also capital contributions
and components of other comprehensive income, including foreign currency
translation. Please tell us how your aggregation of these amounts within the accumulated
deficit balance complies with IAS 1, particularly paragraphs 78(e), 106, and 108. Also
clearly disclose the adjustments to each individual equity line item within the footnotes to
your capitalization table.
FirstName LastNameAndrew Page
Comapany NameAmer Sports, Inc.
January 25, 2024 Page 2
FirstName LastName
Andrew Page
Amer Sports, Inc.
January 25, 2024
Page 2
General
2.Please identify the parties that indicated interest in purchasing shares in the IPO and
ensure that your disclosure on this topic is consistent throughout the prospectus. For
example, on the cover, you indicate that entities "affiliated with" Anta Sports, Anamered,
and Tencent, have indicated an interest in purchasing shares in the IPO but elsewhere,
such as on page 17, you disclose that ANTA Sports, Anamered and Tencent have
indicated interest.
Please contact SiSi Cheng at 202-551-5004 or Andrew Blume at 202-551-3254 if you
have questions regarding comments on the financial statements and related matters. Please
contact Bradley Ecker at 202-551-4985 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing