Errors, Restatements & Item 4.02

Staff comment: We note your accounting policy disclosure on page 70 indicating that you depreciate aircraft over 25 years while using an estimated residual value of 20 percent, although also indicating that for "certain Airbus A320 airframes" you are using a longer period as part of your "capital-light growth" initiative, although without specifying the number of aircraft or the extended range being utilized for depreciation. You provide disclosures on page 13 under the Operations and Cost Structure heading, and on page 43 within the Overview section of MD&A, associating this fleet management initiative with recent plans to secure your financial future and navigate near-term demand volatility. However, on… letter →

Staff comment: We have considered your response to prior comment 1. Given the quantitative significance and pervasiveness of the errors in the financial statements and that full consolidation of the Production Assets you control represents a significant change from how you previously consolidated only your proportional interest in the Production Assets, among other factors, we disagree with your conclusion that the error was immaterial. Accordingly, we continue to believe that your previously issued consolidated financial statements are materially misstated and, therefore, should be restated. letter →

Staff comment: We note your disclosure that as part of the Relocation, on January 31, 2023, you entered into (i) an assignment and assumption agreement with AOUT, pursuant to which AOUT assumed all of your rights, entitlement, and obligations in, to, and under the Missouri Lease, or the Assignment and Assumption Agreement, and (ii) an amended and restated guaranty in favor of RCS-S&W Facility, LLC, as successor in interest to the Original Missouri Landlord, pursuant to which Smith & Wesson Sales Company was added as a guarantor, or the Amended and Restated Guaranty. We also note that because of the Amended and Restated Guaranty, you continue to account for this lease as you have since prior to the… letter →

Staff comment: We acknowledge your response to prior comment two. Please address the following: • Please tell us and revise future filings, as needed, to define "Charged-off Loans" and "Amounts Written Off" clearly identifying the differences between each term as used in your prior reconciliation. • Please provide us a reconciliation showing how the credit loss expense recognized for 2024 and 2023 is presented in the ECL rollforward line-items on page 134. Please separately identify amounts related to each various cause (e.g., "Charged- off Loans" and IAS 29 restatement). • Please consider revising your ECL rollfoward, supporting disclosure or other disclosure in future filings to more clearly show the… letter →

Staff comment: We note your responses to prior comments 1-3. We believe the Production Assets should be accounted for as part of the Jamalco JV. Considering your total assets would increase by approximately 9% and total equity would increase by approximately 20% as a result of accounting for the Production Assets as part of the Jamalco JV, we believe that the error is material. Please restate your financial statements accordingly. letter →

Staff comment: Refer to prior comment 3. You indicate in your response that the errors in multiple reporting periods were related to four discrete items. As the quantitative magnitude of the errors increase, it is increasingly difficult for qualitative factors to overcome the quantitative significance of the errors. Please tell us in further detail how you determined the qualitative factors overcame the quantitative significance of the errors to your Operating Income (Loss) in each of the following periods: • fiscal year ended December 31, 2023, • the three and six months ended June 30, 2025 and • the three and six months ended June 30, 2024. Also, it appears in your quantitative analysis that you have… letter →