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                            March 14, 2023

       Andrew Keegan
       Interim Chief Financial Officer
       Vista Outdoor Inc.
       1 Vista Way
       Anoka, MN 55303

                                                        Re: Vista Outdoor Inc.
                                                            Form 10-K for the
Fiscal Year Ended March 31, 2022
                                                            Filed May 24, 2022
                                                            Form 8-K Filed
February 2, 2023
                                                            File No. 001-36597

       Dear Andrew Keegan:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Fiscal Year Ended March 31, 2022

       Consolidated Statements of Comprehensive Income (Loss), page 41

   1.                                                   We note that you
present the line item    earnings (loss) before interest and income taxes,
                                                        or EBIT, on the face of
your consolidated statements of comprehensive income. Please tell
                                                        us how this
presentation complies with Item 10(e)(1)(ii)(C) of Regulation S-K.
       Form 8-K filed February 2, 2023

       Exhibit 99.1
       General, page 1

   2.                                                   We refer to your
presentation of the non-GAAP measures EBITDA Margin and Free Cash
                                                        Flow in the secondary
headline, as well as the discussion and analysis of EBITDA in the
                                                        body of your earnings
release. In future filings, please revise your disclosures to also
 Andrew Keegan
Vista Outdoor Inc.
March 14, 2023
Page 2
         present, with equal or greater prominence, the most directly
comparable financial
         measures calculated in accordance with GAAP. Refer to Item
10(e)(1)(i)(A) of Regulation
         S-K and Question 102.10(a) of the SEC's Compliance and Disclosure
Interpretations on
         Non-GAAP Financial Measures.
Free Cash Flows, page 6

3.       We note you present a measure described as "free cash flow." It is
unclear what
         information your measure is attempting to convey, as it appears to
conflate elements of
         both liquidity and performance measures. Generally, free cash flow is
understood to be a
         liquidity measure and is presented as cash flows from operating
activities, less capital
         expenditures. At a minimum, it appears you should revise the
description of your measure
         to something other than "free cash flow." In addition, your disclosure
states the measure
         provides investors with information regarding cash available for debt
payments, share
         repurchases and acquisitions. It's unclear how adjustments such as
amounts paid for
         separation costs, transaction costs, etc., are available for purposes
such as debt payments.
         Further, it is unclear why you are also tax effecting your
adjustments, if your measure is
         intended to be a liquidity measure. Please explain the basis for your
measure and why you
         believe it is appropriate or revise the measure accordingly.
       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.

       You may contact Dale Welcome at 202-551-3865 or Kevin Stertzel at
202-551-3723 with
any questions.



FirstName LastNameAndrew Keegan                                Sincerely,
Comapany NameVista Outdoor Inc.
                                                               Division of
Corporation Finance
March 14, 2023 Page 2                                          Office of
Manufacturing
FirstName LastName