SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<TEXT>
 June 26, 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 completed our review of your filing. 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.

 Sincerely,

 Division of Corporation
Finance
 Office of Manufacturing
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 June 20, 2025

 VIA EDGAR

 Andi Carpenter

 Anne McConnell

 Division of Corporation Finance

 Office of Manufacturing

 United States Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Re: Amer
Sports, Inc.

 Form 20-F for The Fiscal Year Ended December
31, 2024

 Filed March 7, 2025

 File No. 001-41943

 Dear Staff:

 This letter is in response to the comment letter
from the staff (the "Staff") of the Securities and Exchange Commission (the "SEC" or the "Commission")
on the above-referenced filing of Amer Sports, Inc. ("Amer Sports" or the "Company") made in your letter dated
June 9, 2025. Please note that the "Company" refers to Amer Sports, Inc., together with its consolidated subsidiaries. Set
forth below are the Staff's comments in italics, followed in each case by the response of the Company. All terms used but not defined
herein have the meanings assigned to such terms in the Form 20-F.

 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.

 Response:

 The Company respectfully acknowledges the Staff's
comment and in future filings will revise its disclosure to remove EBITDA from its reconciliation of Net Income (Loss) to Adjusted EBITDA
and update its definition of Adjusted EBITDA accordingly. If the Company determines to disclose EBITDA in the future, it will only present
adjustments specifically identified by the acronym.

 Amer Sports, Inc.

 149 Fifth Avenue, 9th Floor

 New York, NY 10010

 Tel. +1 773 714-6400

 www.amersports.com

 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, 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.

 Response:

 The Company acknowledges the Staff's comment
and respectfully submits the following rationale for the Purchase Price Adjustment included in our determination of Adjusted Net Income
(Loss) and certain other non-IFRS measures. This adjustment relates to amortization and depreciation arising from the step-up
in fair value of intangible and tangible assets following the 2019 acquisition of Amer Sports.

 The specific facts and circumstances related to
the Company's acquisition history are a determining factor for understanding the components of the adjustment, how each amount was
determined, and why the Company believes the adjustment is appropriate and complies with Question 100.04 of the Compliance & Disclosures
Interpretations on Non-GAAP Financial Measures.

 In 2019, Amer Sports was acquired by an international
investment consortium (the "Acquisition"). In connection with the Acquisition, all identifiable assets and liabilities
were recorded at their acquisition date fair values in accordance with IFRS 3, Business Combinations . This resulted in the recognition
of previously unrecorded finite-lived intangible assets (i.e. customer relationships and other technology-based intangibles), as well
as a step-up in the fair value of property, plant and equipment (primarily machinery, equipment, buildings, and leasehold improvements).
The underlying business remained materially unchanged; therefore, the fair value adjustments stemmed solely from the ownership change,
not from business combinations executed by the Company.

 The adjustment to arrive at the non-IFRS financial
measures presented includes all amortization of previously unrecorded finite-lived intangible assets and incremental depreciation on the
step-up in property, plant and equipment. These assets are amortized and depreciated on a straight-line basis over their useful
lives. Since these assets arose entirely from the Acquisition, the full amortization and depreciation amounts are included in the adjustment
- the Company's presentation does not reflect a partial exclusion. Importantly, the adjustments are calculated in accordance
with IFRS and do not represent an alternative recognition or measurement methodology.

 The components of the adjustment are as follows:

 The Company believes the amortization and depreciation
related to the purchase accounting adjustments distort the comparability with its peer group, as the Acquisition was a one-time change
of control event. We submit that excluding these effects enhances comparability and provides meaningful disclosure to investors. Moreover,
this adjustment aligns with the Segment Adjusted Operating Profit metric used by our Chief Operating Decision Maker to assess performance
and allocate resources. The Company believes reflecting this adjustment in its presentation of certain non-IFRS measures more appropriately
reflects how management evaluates results and is an important complement to its reported IFRS financials.

 Item 19. 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.

 Response:

 The Company respectfully acknowledges that the
introductory language in paragraph 4 regarding the officers' responsibilities for establishing and maintaining internal control
over financial reporting was inadvertently excluded from the certifications filed as Exhibits 12.1 and 12.2 to the Form 20-F. The Company
will 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.

 We appreciate the Staff's time and attention
on this matter. If you have any questions or comments regarding the foregoing, please do not hesitate to contact me.

 Sincerely,

 /s/ Andrew E. Page

 Andrew E. Page

 Chief Financial Officer

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<TEXT>
 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
</TEXT>
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CORRESP
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BofA Securities, Inc.

One Bryant Park

New York, New York 10036

J.P. Morgan Securities LLC

 383 Madison Avenue

New York, New York 10179

December 2, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:	     Jenny
O’Shanick

Re: Amer Sports, Inc.

Registration Statement on Form F-1

Filed December 2, 2024

File No. 333-283554

Acceleration Request

Requested Date: December 4, 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 December 4,
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 we 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,

  BofA Securities, Inc.

  J.P. Morgan Securities LLC,

  As Representatives of the several Underwriters

  BOFA SECURITIES, INC.

  By:
  /s/ Blake Hallinan

  Name:
  Blake Hallinan

  Title:
  Managing Director

  J.P. MORGAN SECURITIES LLC

  By:
  /s/ Brittany Collier

  Name:
  Brittany Collier

  Title:
  Managing Director

[Signature Page to Underwriters’
Acceleration Request Letter]

CORRESP
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Amer Sports, Inc.

Cricket Square, Hutchins Drive,

P.O. Box 2681

Grand Cayman, KY1-1111

Cayman Islands

T +1 345 945 3901

    December 2, 2024

    VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Amer Sports, Inc. (the “Company”)

Registration Statement on Form F-1

Registration No. 333-283554

Attention: Ms. Jenny O’Shanick

Dear Ms. O’Shanick:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, the undersigned registrant hereby requests that the effective date for
the Registration Statement referred to above be accelerated so that it will be declared effective at 4:00 p.m. Eastern Time
on December 4, 2024 or at such later time as the Company or its counsel may orally request
via telephone call to the staff of the Securities and Exchange Commission. By separate letter, the underwriters of the issuance of the
securities being registered join in this request for acceleration.

Please do not hesitate to contact Roshni Banker Cariello of Davis Polk &
Wardwell LLP at (212) 450-4421 or roshni.cariello@davispolk.com with any questions with respect to this letter.

    Sincerely,

    Amer Sports, Inc.

    By:
    /s/ Andrew E. Page

    Name:
    Andrew E. Page

    Title:
    Chief Financial Officer

November 18, 2024
Jie (James) Zheng
Chief Executive Officer
Amer Sports, Inc.
Cricket Square, Hutchins Drive,
P.O. Box 2681,
Grand Cayman, KY1-1111,
Cayman Islands
Re:Amer Sports, Inc.
Draft Registration Statement on Form F-1
Submitted November 15, 2024
CIK No. 0001988894
Dear Jie (James) Zheng:
            This is to advise you that we do not intend to review your registration statement.
            We request that you publicly file your registration statement no later than 48 hours
prior to the requested effective date and time. Please refer to Rules 460 and 461 regarding
requests for acceleration. 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 Jenny O'Shanick at 202-551-8005 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Roshni Banker Cariello

CORRESP
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Amer Sports, Inc.

Cricket Square, Hutchins Drive,

P.O. Box 2681

Grand Cayman, KY1-1111

Cayman Islands

T +1 345 945 3901

January 29, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Amer Sports, Inc. (the “Company”)

Registration Statement on Form F-1

Registration No. 333-276370

Attention: Mr. Bradley Ecker and Mr. Jay Ingram

Dear Mr. Ecker and Mr. Ingram:

Pursuant to Rule 461 under the Securities Act of 1933, as amended,
the undersigned registrant hereby requests that the effective date for the Registration Statement referred to above be accelerated so
that it will be declared effective at 4:00 p.m. Eastern Time on January 31, 2024 or at such later time as the Company or its counsel may
orally request via telephone call to the staff of the Securities and Exchange Commission. By separate letter, the underwriters of the
issuance of the securities being registered join in this request for acceleration.

Please do not hesitate to contact Michael Kaplan of Davis Polk &
Wardwell LLP at (212) 450-4111 or michael.kaplan@davispolk.com with any questions with respect to this letter.

Sincerely,

Amer Sports, Inc.

By:
/s/ Andrew E. Page

Name:   Andrew E. Page

Title:     Chief Financial Officer

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]

CORRESP
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    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 26, 2024

    Re:
    Amer Sports, Inc.

Amendment No. 1 to Registration Statement on Form F-1

Filed January 22, 2024

File No. 333-276370

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 Mr. Ecker 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 comments from the Staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) relating to the Company’s Amendment No.1 to the
Registration Statement on Form F-1, as filed with the Commission on January 22, 2024 (the “Registration Statement”)
contained in the Staff’s letter dated January 25, 2024 (the “Comment Letter”). In response to the comments
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 are the Company’s responses to the Staff’s
comments. For convenience, the Staff’s comments are repeated below in italics, followed by the Company’s response to each
comment. We have included page numbers to refer to the location in the Revised Registration Statement, filed on the date hereof,
where revised language addressing a particular comment appears. Unless otherwise indicated, capitalized terms used herein have the meanings
assigned to them in the Revised Registration Statement.

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.

Response:	     The
Company respectfully acknowledges the Staff’s comment and advises the Staff that the Company has revised its presentation of the
consolidated statement of changes in shareholders' equity (deficit) on pages F-6 and F-32 to reflect the Staff’s comment that
the line item accumulated deficit should not reflect capital contributions and components of other comprehensive income by presenting
such transactions in the equity category “other reserves.” The Company has also clarified the presentation of the consolidated
statement of changes in shareholders’ equity (deficit) by renaming the equity categories “accumulated deficit for the period”
and “accumulated deficit (total)” to “accumulated deficit” and “accumulated deficit and other,” respectively.
Further, the Company has clarified the presentation of the consolidated statement of financial position on pages F-4 and F-30 by
renaming the line item “accumulated deficit” to “accumulated deficit and other” to align to the presentation in
the consolidated statement of changes in shareholders' equity (deficit).

In addition, the Company has revised the footnotes of its consolidated
financial statements to present in a table the components that comprise “accumulated deficit and other” recorded on the face
of the consolidated statement of financial position on pages F-18 and F-73. The Company believes this presentation is permitted and
provided by IAS 1.78 and 1.77. IAS 1.77 states that "an entity shall disclose, either in the statement of financial position or
in the notes [emphasis added], further subclassifications of the line items presented, classified in a manner appropriate to the entity
operations.”

In response to the Staff’s comment, the Company has also revised
its disclosure in the footnotes to the capitalization table on pages 81, 82 and 83 to clearly disclose the adjustments to each individual
equity line item.

 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.

Response:	     In
response to the Staff’s comment, the Company has revised its disclosure on the cover page and on pages 17, 24, 70, 176, 204, 205 and 207 of the 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 26, 2024 2

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

CORRESP
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    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

United States securities and exchange commission logo
January 18, 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.
Registration Statement on Form F-1
Filed January 4, 2024
File No. 333-276370
Dear Andrew Page:
            We have reviewed your registration statement and have the following comment.
            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.
Registration Statement on Form F-1
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.

 FirstName LastNameAndrew Page
 Comapany NameAmer Sports, Inc.
 January 18, 2024 Page 2
 FirstName LastName
Andrew Page
Amer Sports, Inc.
January 18, 2024
Page 2
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            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

United States securities and exchange commission logo
September 29, 2023
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 Draft Registration Statement on Form F-1
Submitted September 18, 2023
CIK No. 0001988894
Dear Andrew Page:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form F-1
Shareholder Loan Equitization, page 16
1.Please provide a materially complete description of the mechanics of the "Shareholder
Loan Equitization" and explain how the debt will be "effectively forgiven."  Provide a
clear description of how funds from the offering will be utilized to implement the plan,
identify all of the parties involved in the transactions, and file the agreements associated
with the plan as exhibits to the registration statement.

 FirstName LastNameAndrew Page
 Comapany NameAmer Sports, Inc.
 September 29, 2023 Page 2
 FirstName LastName
Andrew Page
Amer Sports, Inc.
September 29, 2023
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations
Comparability of Our Results of Operations
Key Financial Metrics, page 84
2.We note your updated disclosure on page 97 in response to prior comment 9.  Please also
revise your table on page 85 to present the comparable IFRS measure, net loss margin,
with equal or greater prominence to your non-IFRS measure Adjusted EBITDA Margin.
Refer to Item 10(e)(1)(i)(A) of Regulation S-K.

3.We note your response to prior comment 10.  Please either segregate the applicable line
items within your non-IFRS reconciliations between continuing and discontinued
operations or include the table provided within your response that specifically
identifies the reconciliation amounts related to discontinued operations.
Index to Consolidated Financial Statements, page F-1
4.Please note the financial statement updating requirements provided in Item 8.A.5 of Form
20-F.
            You may 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

United States securities and exchange commission logo
September 8, 2023
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.
Draft Registration Statement on Form F-1
Submitted August 11, 2023
CIK No. 0001988894
Dear Andrew Page:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 filed August 11, 2023
Summary, page 1
1.Please revise your summary to present an objective description of the challenges and/or
weaknesses of your business and operations.  For example, you highlight your competitive
strengths and brand awareness without equally prominent disclosure regarding your
weaknesses.
Our Market Opportunity, page 14
2.We note that the prospectus includes market, industry, and other data based on

 FirstName LastNameAndrew Page
 Comapany NameAmer Sports, Inc.
 September 8, 2023 Page 2
 FirstName LastNameAndrew Page
Amer Sports, Inc.
September 8, 2023
Page 2
information from third-party sources.  Please tell us if you commissioned any of the
industry or other data that you reference and, if so, please file consents of such third
parties pursuant to Rule 436 of the Securities Act as exhibits to your registration statement
or advise.
Summary Financial and Other Information
Summary Loss and Other Comprehensive Income and Loss Data, page 22
3.Considering the information appears currently available, please populate your loss per
share and weighted average number of ordinary shares outstanding amounts in the table.

4.Please revise footnote (2) to clearly describe and quantify adjustments made to determine
the pro forma loss and pro forma loss per ordinary shares amounts.

Risks Related to Our Class A Ordinary Shares and this Offering, page 62
5.Please consider disclosing the risks to holders of your Class A Ordinary Shares that future
issuances of your Class B Ordinary Shares may be dilutive to Class A shareholders.
Capitalization, page 73
6.Please address the following items related to your capitalization table:
•Place a double line beneath the cash and cash equivalents line item to distinguish it
from total capitalization;
•Revise to include all indebtedness, including your short-term borrowings;
•Revise to give effect to the expected repayment and cancellation of your shareholder
loans in connection with the offering.  Ensure you tell us and disclose your
accounting treatment for any gains or losses associated with such transactions; and
•Revise to separately discuss and quantify each of the pro forma adjustments.
Segment Results of Operations
Technical Apparel, page 93
7.Please populate the comparable sales growth percentages.
Non-IFRS Financial Measures, page 96
8.We note that your Adjusted Net Income and Adjusted EBITDA reconciliations include an
adjustment for expenses related to certain significant legal proceedings.  Please tell us and
disclose the specific facts and circumstances related to these expenses and explain how
you concluded that these expenses are not normal, recurring, cash operating expenses of
your business and that eliminating them within your Non-IFRS financial measures is
meaningful and appropriate.  Refer to Question 100.01 of the SEC’s Compliance and
Disclosure Interpretations for Non-GAAP Financial Measures for guidance.  To the extent
any of the significant legal proceedings are still pending, tell us how you considered the

 FirstName LastNameAndrew Page
 Comapany NameAmer Sports, Inc.
 September 8, 2023 Page 3
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Amer Sports, Inc.
September 8, 2023
Page 3
disclosure requirements of IAS 37.84-92 and 1(c)(v) of Instructions as to Summary
Prospectuses of Form F-1.
9.Although we acknowledge your disclosures on page iv regarding the reasons why you do
not present net loss margin, Item 10(e)(1)(i)(A)-(B) requires the presentation of and
reconciliation to the most directly comparable IFRS measure.  Please revise your filing to
comply with such disclosure requirements.
10.We note that certain amounts within the income tax expense and finance costs line items
of your Adjusted EBITDA reconciliation do not agree to the face of your consolidated
statement of loss.  Please revise your presentation accordingly or tell us what the
differences represent.
11.Pursuant to Question 102.11 of the SEC’s Compliance and Disclosure Interpretations for
Non-GAAP Financial Measures, please revise your Adjusted Net Income reconciliation
on page 97 to present each adjustment on a pre-tax basis with a separate adjustment for
income taxes.  Ensure that you clearly explain how you calculated the income tax effect.
Liquidity and Capital Resources, page 98
12.We note your disclosure that you are expecting increased capital expenditures related to
the upgrade of your global SAP enterprise resource planning system and the expansion of
your warehousing facilities.  Please expand your disclosure to quantify your estimated
capital expenditure requirements for the next twelve months.  See Item 303(b)(1) of
Regulation S-K.
Supply Chain, page 131
13.We note your disclosure that Gore-Tex is used in your Arc'teryx products. Please clarify
whether Gore-Tex is also used across your other brands, and to what extent.
Notes to the Consolidated Financial Statements
Revenue recognition, page F-14
14.We note your disclosures on pages 13 and 119 that Salomon and Arc'teryx offer customer
loyalty programs.  Please tell us and, to the extent material, disclose how you account for
such loyalty programs, including whether or not they represent a material right and a
separate performance obligation under IFRS 15.
15.We note that "guarantee revenue" related to certain licensing agreements is recognized at
the point in time when control of the license is transferred.  Please tell us the nature and
terms of these licensing agreements and how you determined point in time recognition
was appropriate under IFRS 15.
9. Depreciation, Amortization and Impairment Losses, page F-35
16.We note that the depreciation and amortization totals included in this footnote, the

 FirstName LastNameAndrew Page
 Comapany NameAmer Sports, Inc.
 September 8, 2023 Page 4
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Amer Sports, Inc.
September 8, 2023
Page 4
statement of cash flows, and within your segment footnote are internally inconsistent.
Please revise your filing accordingly or tell us the reasons for each variance.  Also ensure
you reconcile the depreciation and amortization totals for your reportable segments to the
corresponding consolidated amounts pursuant to IFRS 8.28.
29. Discontinued Operations and Assets and Liabilities Held For Sale, page F-75
17.Please tell us in sufficient detail how the disposition of Suunto qualified for discontinued
operations classification pursuant to IFRS 5.32.  In particular, explain how you
determined the disposal represented a separate major lines of business or geographical
area and clarify if Suunto represented a cash-generating unit ("CGU") or a group of
CGU's.  Per the tables on pages F-76-77, we note that the assets and liabilities held for
sale at fiscal year-end 2021 were not material to consolidated amounts.
Exhibits
18.We note your disclosure that you rely on a sole source supplier for Gore-Tex. Please tell
us what consideration you gave to Item 601(b)(10) of Regulation S-K.
General
19.Please disclose whether and how your business segments, products, lines of service,
projects, or operations are materially impacted by supply chain disruptions, especially in
light of Russia's invasion of Ukraine.  For example, discuss whether you have or expect
to:
•Suspend the production, purchase, sale or maintenance of certain items due to a lack
of raw materials, parts, or equipment; inventory shortages; closed factories or stores;
reduced headcount; or delayed projects;
•experience labor shortages that impact your business;
•experience cybersecurity attacks in your supply chain;
•experience higher costs due to constrained capacity or increased commodity prices or
challenges sourcing materials;
•experience surges or declines in consumer demand for which you are unable to
adequately adjust your supply; or
•Be unable to supply products at competitive prices or at all.
Explain whether and how you have undertaken efforts to mitigate the impact and where
possibly quantify the impact to your business.
20.Please tell us why Tencent's interests in Amer Sports Holding (Cayman) Limited are not
included in the reclassification and distribution transactions you describe.
21.Please provide us supplemental copies of all written communications as defined in Rule
405 under the Securities Act that you or anyone authorized to do so on your behalf have
presented or expect to present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not you retained or intend to retain copies of those
communications. Please contact the legal staff associated with the review of this filing to

 FirstName LastNameAndrew Page
 Comapany NameAmer Sports, Inc.
 September 8, 2023 Page 5
 FirstName LastName
Andrew Page
Amer Sports, Inc.
September 8, 2023
Page 5
discuss how to submit the materials, if any, to us for our review.
22.We note your disclosure that ANTA Sports will be a controlling shareholder after
completion of the offering. Please revise, wherever applicable, to describe the risks
associated with your controlling shareholder's being based in China, including your
Enforceability of Civil Liabilities section. In this regard, we note your disclosure on page
33 that "The PRC government has significant authority to exert influence on the ability of
companies with Chinese operations to conduct their business."
            You may 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