October 17, 2019

Jeffrey D. Buchanan
Chief Financial Offier
AMERICAN OUTDOOR BRANDS CORP
2100 Roosevelt Avenue
Springfiled, MA 01104

       Re: AMERICAN OUTDOOR BRANDS CORP
           Form 10-K for the Year Ended April 30, 2019
           File No. 001-31552

Dear Mr. Buchanan:

       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 Year Ended April 30, 2019

3. Significant Accounting Policies
Valuation of Long-Lived Tangible and Intangible Assets, page F-14

1.    You disclose that during the third quarter of fiscal year 2019, you
recorded a $10.4 million
      goodwill impairment in your Electro-Optics reporting unit which was
subsequently
      restructured and combined into your Outdoor Products & Accessories
reporting unit.
      Please more fully address the following:
        Tell us the amount of goodwill allocated to the Electro-Optics
reporting unit before
           and after the impairment;
        Explain the specific facts and circumstances that lead you to
restructure and combine
           the two reporting units;
        Tell us whether you performed a goodwill impairment analysis
immediately after the
           reorganization. If not, explain why;
        Provide us summarized financial information for each of the two
reporting units; and
        Tell us the key assumptions and estimates that lead to your
determination that the fair
           value of the Outdoor Products & Accessories reporting unit
substantially exceeded its
 Jeffrey D. Buchanan
AMERICAN OUTDOOR BRANDS CORP
October 17, 2019
Page 2
              carrying value as of your test date and explain how the
reorganization impacted your
              assessment.
2.       We note that your current market capitalization is significantly below
your net book
         value. Please tell us if you have performed an interim goodwill
impairment analysis
         subsequent to April 30, 2019, and if so, please tell us the results of
your analysis. If an
         interim goodwill impairment analysis has not been performed, please
explain why you do
         not believe one was required given the weakness in market conditions
and the sustained
         decline in your stock price and market capitalization.
       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 SiSi Cheng at 202-551-5004 or Anne Mcconnell at
202-551-3709 with
any questions.



FirstName LastNameJeffrey D. Buchanan   Sincerely,
Comapany NameAMERICAN OUTDOOR BRANDS CORP
                                        Division of Corporation Finance
October 17, 2019 Page 2                 Office of Manufacturing
FirstName LastName