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SEC Comment Letter for GSI COMMERCE INC (CIK 0000828750) — Jun 1, 2005

GSI COMMERCE INC (CIK 0000828750)
Date: June 1, 2005 · CIK: 0000828750 · Accession: 0000000000-05-026933

AI Filing Summary & Sentiment

Date
May 5, 2005
Author
Anthony Watson
Form
UPLOAD
Company
GSI COMMERCE INC (CIK 0000828750)

Letter

May 5, 2005 By Facsimile and U.S. Mail Mr. Jordan Copland Chief Financial Officer GSI Commerce, Inc. 935 First Avenue King of Prussia, PA 19406

RE: GSI Commerce, Inc. Item 4.02 Form 8-K filed May 4, File No. 0-16611

Dear Mr. Copland:

We have reviewed your Item 4.02 Form 8-K for compliance with the form requirements and have the following comments.

1. Please amend your report to disclose the amount of the restatement for the specific periods involved. 2. Please tell us if your certifying officers have reconsidered the effect on the adequacy of your disclosure controls and procedures as of the end of the period covered by your Form 10-K for the fiscal years ended January 1, 2005, January 3, 2004 and December 28, 2002 in light of the restatement you have disclosed. Additionally, tell us what effect the restatement had on your current evaluation of internal controls over financial reporting as of your fiscal year end January 1, 2005.

You should file an amendment in response to this comment on or before May 12, 2005.

If you have any questions regarding these comments, please direct them to Anthony Watson, Staff Accountant, at (202) 551-3318.

Sincerely,
Anthony Watson
Staff Accountant

Show Raw Text
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<TEXT>

May 5, 2005

By Facsimile and U.S. Mail

Mr. Jordan Copland
Chief Financial Officer
GSI Commerce, Inc.
935 First Avenue
King of Prussia, PA 19406

		RE:	GSI Commerce, Inc. Item 4.02 Form 8-K filed May 4,
2005
			File No.  0-16611

Dear Mr. Copland:

	We have reviewed your Item 4.02 Form 8-K for compliance with
the
form requirements and have the following comments.

1. Please amend your report to disclose the amount of the
restatement
for the specific periods involved.
2. Please tell us if your certifying officers have reconsidered
the
effect on the adequacy of your disclosure controls and procedures
as
of the end of the period covered by your Form 10-K for the fiscal
years ended January 1, 2005, January 3, 2004 and December 28, 2002
in
light of the restatement you have disclosed.  Additionally, tell
us
what effect the restatement had on your current evaluation of
internal controls over financial reporting as of your fiscal year
end
January 1, 2005.

You should file an amendment in response to this comment on or
before
May 12, 2005.

If you have any questions regarding these comments, please direct
them to Anthony Watson, Staff Accountant, at (202) 551-3318.

							Sincerely,

							Anthony Watson
						Staff Accountant

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May 5, 2005
Page 1

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