Correspondence 0001104659-24-007655 from Amer Sports, Inc. (AS)
Amer Sports, Inc.
Date: Jan. 29, 2024 · CIK: 0001988894 · Accession: 0001104659-24-007655
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File numbers found in text: 333-276370
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CORRESP
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Goldman Sachs & Co. LLC
200 West Street
New York, New York 10282
BofA Securities, Inc.
One Bryant Park
New York, New York 10036
J.P. Morgan Securities LLC
383 Madison Avenue
New York, New York 10179
Morgan Stanley & Co. LLC
1585 Broadway
New York, New York 10036
January 29, 2024
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Bradley Ecker
Jay Ingram
SiSi Cheng
Andrew Blume
Re: Amer Sports, Inc.
Registration Statement on Form F-1
Filed January 4, 2024, as amended
File No. 333-276370
Acceleration Request
Requested Date: January 31, 2024
Requested Time: 4:00 P.M. Eastern Time
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act
of 1933, as amended (the “Securities Act”), we, as the representatives of the several underwriters (the “Representatives”),
hereby join in the request of Amer Sports, Inc., an exempted company incorporated under the laws of the Cayman Islands with limited liability
(the “Company”), that the effective date of the above-referenced Registration Statement on Form F-1 be accelerated so that
it will be declared effective at 4:00 p.m. Eastern Time, on January 31, 2024, or as soon thereafter as practicable, or at such other time
thereafter as the Company or its outside counsel, Davis Polk & Wardwell LLP, may request by telephone to the staff of the Securities
and Exchange Commission.
Pursuant to Rule 460 under the Securities Act,
we, as the Representatives, wish to advise you that we will take reasonable steps to secure adequate distribution of the preliminary prospectus
to underwriters, dealers, institutions and others prior to the requested effective time of the Registration Statement.
We, the undersigned Representatives, hereby represent
that we are in compliance and will comply, and have been informed by the other participating underwriters that they are in compliance
and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the offering
pursuant to the above-referenced Registration Statement and Preliminary Prospectus.
[Signature Page Follows]
Very truly yours,
Goldman Sachs & Co. LLC
BofA Securities, Inc.
J.P. Morgan Securities LLC
Morgan Stanley & Co. LLC,
As Representatives of the several
Underwriters
GOLDMAN SACHS & CO. LLC
By:
/s/ Timothy Carson
Name: Timothy Carson
Title: Managing Director
BOFA SECURITIES, INC.
By:
/s/ Michael Liloia
Name: Michael Liloia
Title: Director
J.P. MORGAN SECURITIES LLC
By:
/s/ Ratnabali Majumdar
Name: Ratnabali Majumdar
Title: Vice President
MORGAN STANLEY & CO. LLC
By:
/s/ Josh Kamboj
Name: Josh Kamboj
Title: Executive Director, Global
Capital Markets
[Signature Page to Underwriters’
Acceleration Request Letter]