Correspondence 0001104659-24-005373 from Amer Sports, Inc. (AS)
Amer Sports, Inc.
Date: Jan. 22, 2024 · CIK: 0001988894 · Accession: 0001104659-24-005373
AI Filing Summary & Sentiment
Reasoning
Referenced dates: January 18, 2024
Letter
Division of Corporation Finance Office of Manufacturing U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549-3628
Dear Ms. Cheng and Mr. Blume:
On behalf of our client, Amer Sports, Inc., a Cayman Islands exempted company with limited liability (the “Company”), we are responding to the comment from the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to the Company’s Registration Statement on Form F-1, as filed with the Commission on January 4, 2024 (the “Registration Statement”) contained in the Staff’s letter dated January 18, 2024 (the “Comment Letter”). In response to the comment set forth in the Comment Letter, the Company has revised the Registration Statement (the “Revised Registration Statement”) and is filing it together with this response letter. The Revised Registration Statement also contains certain additional updates and revisions.
Set forth below is the Company’s response to the Staff’s comment. For convenience, the Staff’s comment is repeated below in italics, followed by the Company’s response. Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in the Revised Registration Statement.
Registration Statement on Form F-1 filed January 4, 2024
Index to Consolidated Financial Statements, page F-1
1. Pursuant to Item 8.A.4 of Form 20-F, please provide audited financial statements that are no more than twelve months old. Alternatively, to the extent you meet the 15-month criteria outlined in Instruction 2 to Item 8.A.4, file the necessary representations as an exhibit to the registration statement
Response: In response to the Staff’s comment, the Company has filed its application for waiver and representation under Form 20-F, Instruction 2 to Item 8.A.4 as Exhibit 99.10 to its Revised Registration Statement.
Should any questions arise, please do not hesitate to contact me at (212) 450-4111 (tel) or michael.kaplan@davispolk.com, or Roshni Banker Cariello at (212) 450-4421 (tel) or roshni.cariello@davispolk.com. Thank you for your time and attention.
Very truly yours,
/s/ Michael Kaplan
Show Raw Text
CORRESP
1
filename1.htm
Michael
Kaplan
+1 212 450 4111
michael.kaplan@davispolk.com
Davis
Polk & Wardwell llp
450 Lexington Avenue
New York, NY 10017
davispolk.com
Confidential
January 22, 2024
Re:
Amer Sports, Inc.
Registration Statement on Form F-1
Filed January 4, 2024
CIK No. 0001988894
Bradley Ecker, Jay Ingram
SiSi Cheng, Andrew Blume
Division of Corporation Finance
Office of Manufacturing
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-3628
Dear Ms. Cheng and Mr. Blume:
On behalf of our client, Amer Sports, Inc., a Cayman Islands
exempted company with limited liability (the “Company”), we are responding to the comment from the Staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) relating to the Company’s Registration Statement
on Form F-1, as filed with the Commission on January 4, 2024 (the “Registration Statement”) contained in
the Staff’s letter dated January 18, 2024 (the “Comment Letter”). In response to the comment set forth
in the Comment Letter, the Company has revised the Registration Statement (the “Revised Registration Statement”) and
is filing it together with this response letter. The Revised Registration Statement also contains certain additional updates and revisions.
Set forth below is the Company’s response to the Staff’s
comment. For convenience, the Staff’s comment is repeated below in italics, followed by the Company’s response. Unless otherwise
indicated, capitalized terms used herein have the meanings assigned to them in the Revised Registration Statement.
Registration Statement on Form F-1 filed January 4, 2024
Index to Consolidated Financial Statements, page F-1
1. Pursuant to Item 8.A.4 of Form 20-F, please provide
audited financial statements that are no more than twelve months old. Alternatively, to the
extent you meet the 15-month criteria outlined in Instruction 2 to Item 8.A.4, file the necessary
representations as an exhibit to the registration statement
Response: In
response to the Staff’s comment, the Company has filed its application for waiver and representation under Form 20-F, Instruction
2 to Item 8.A.4 as Exhibit 99.10 to its Revised Registration Statement.
Should any questions arise, please do not hesitate to contact me at
(212) 450-4111 (tel) or michael.kaplan@davispolk.com, or Roshni Banker Cariello at (212) 450-4421 (tel) or roshni.cariello@davispolk.com.
Thank you for your time and attention.
Very truly yours,
/s/ Michael Kaplan
Michael Kaplan
cc:
Roshni Banker Cariello, Davis Polk & Wardwell LLP
Andrew Page, Chief Financial Officer, Amer Sports, Inc.
January 22, 2024
2