SRSEC Reporting Desk

Under Armour, Inc. (UA, UAA) – Company response

2026-03-23 · Re: Form 10-K for the Fiscal Year Ended March 31, 2025 Filed May 22, 2025 · Accession 0001336917-26-000043 · Agreed to revise

Responds to staff letter of 2026-03-11.

Segment Reporting (ASC 280)Goodwill & Asset ImpairmentFair Value & Investments

2026-03-11 · Form 10-K for the Fiscal Year Ended March 31, 2025 Filed May 22, 2025 · Comment 1 · Goodwill and Indefinite-Lived Intangible Assets, page 54 Agreed to revise
Staff comment: We note your disclosure that in conducting an annual impairment test, you first review qualitative factors to determine whether it is more likely than not that the fair value of the reporting unit or indefinite-lived intangible asset is less than its carrying amount, and if factors indicate that is the case, or if you choose to bypass the qualitative assessment, you perform a quantitative impairment test. We further note that no goodwill impairments were recorded during Fiscal 2025, Fiscal 2024 or Fiscal 2023. Please revise your disclosures to ensure that you include an accounting policy addressing how you assess goodwill and intangible assets for impairment. Your disclosures should… letter →
Company response: 1. The Company respectfully acknowledges the Staff’s comment and undertakes to revise our future filings, beginning with its Annual Report on Form 10-K for the year ending March 31, 2026, to enhance and expand its accounting policy disclosures related to goodwill and indefinite-lived intangible asset impairment in Note 2 to its Consolidated Financial Statements and within the Critical Accounting Estimates discussion within Management’s Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”). For example, in any period that goodwill is impaired and considered a non-recurring fair value measurement, the Company will include the applicable ASC 820 disclosures, such as… response letter →
Segment Reporting (ASC 280)Goodwill & Asset ImpairmentFair Value & Investments

Full letter on EDGAR → · Filing index · All Under Armour, Inc. (UA, UAA) correspondence

Segment Reporting (ASC 280) – what to check: Check ASU 2023-07 significant segment expense disclosure, CODM identification, and that MD&A segment discussion matches the ASC 280 note.

Goodwill & Asset Impairment – what to check: Disclose reporting units at risk, headroom, key assumptions and triggering-event analysis, especially if market cap is below book value.

Fair Value & Investments – what to check: Disclose Level 3 valuation techniques and significant unobservable inputs, and support equity-method vs. fair value elections.

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