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 June 9, 2025

Andrew E. Page
Chief Financial Officer
Amer Sports, Inc.
149 Fifth Avenue, 9th Floor
New York, New York 10010

 Re: Amer Sports, Inc.
 Form 20-F for The Fiscal Year Ended December 31, 2024
 Filed March 7, 2025
 File No. 001-41943
Dear Andrew E. Page:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 20-F for The Fiscal Year Ended December 31, 2024
Item 5. Operating and Financial Review and Prospects
Non-IFRS Financial Measures, page 94

1. We note the measure you identify as EBITDA includes several adjustments
in
 addition to the items specifically identified by the acronym. Please
revise future
 filings to present all adjustments not specifically identified by the
acronym below
 EBITDA such that those adjustments are only included in the
determination of
 Adjusted EBITDA. Refer to Question 103.01 of the Compliance &
Disclosures
 Interpretations on Non-GAAP Financial Measures. This comment is also
applicable to
 your presentation of EBITDA and Adjusted EBITDA in Form 6-Ks.
2. We note the Purchase Price Adjustment in your determination of Adjusted
Net
 Income (Loss) appears to result in you excluding amortization and
depreciation on fair
 value adjustments of intangible and tangible assets from Amer Sports'
acquisition in
 2019. It appears to us that this adjustment results in presenting a
non-IFRS financial
 measure that substitutes individually tailored recognition and
measurement methods,
 June 9, 2025
Page 2

 given you exclude partial amortization and depreciation related to the
step-up in fair
 value of intangible and tangible assets acquired in a business
combination which
 essentially removes the impact of the acquisition method of accounting.
Please revise
 future filings to remove this adjustment or more fully explain to us
each component of
 the adjustment, how each amount was determined, and why you believe the
 adjustment is appropriate and complies with Question 100.04 of the
Compliance
 & Disclosures Interpretations on Non-GAAP Financial Measures. This
comment is
 also applicable to Purchase Price Adjustments related to this measure
and several
 additional non-IFRS financial measures presented in your Form 6-Ks.
Item19. Exhibits, page 151

3. We note the officer certifications included in Exhibits 12.1 and 12.2
exclude the
 introductory language in paragraph 4 regarding the officers'
responsibilities for
 establishing and maintaining internal control over financial reporting.
Please revise
 future filings to ensure each Section 302 certification includes all the
prescribed
 language set forth in paragraph 12 of the "Instructions as to Exhibits"
of Form 20-F.
 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Andi Carpenter at 202-551-3645 or Anne McConnell at
202-551-3709
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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