SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3561

       June 29, 2007

Mr. Timothy E. Kullman
Chief Financial Officer
Dick’s Sporting Goods, Inc.
300 Industry Drive
RIDC Park West
Pittsburgh, Pennsylvania 15275

Re:  Dick’s Sporting Goods, Inc.
Item 4.02 Form 8-K
Filed June 5, 2007
File No. 1-31463

Dear Mr. Kullman:

 We reviewed your responses to our prior comments on the above referenced filing as set forth in your letter dated June  21, 2007.  Our review resulted in the following
additional comments.

Form 8-K Filed June 5, 2007

1. We reviewed your response to comment one from our letter dated June 7, 2007.
Regarding your accounting policies for cons truction allowances received prior to
a store’s grand opening where you are deem ed the owner during the construction
period and which qualifies for sale-leas eback accounting upon completion of
construction, please explain to us your ba sis for presenting cash received prior to
the grand opening as operating cash infl ows and your basis for reclassifying
amounts previously reflected in operati ng cash flows to proceeds from sale-
leaseback transactions in investing cash fl ows.  It appears to us that the reduction
in the non-cash obligation for construction in progress – leased facilities (or
deferred construction allowances) upon a sale-leaseback transaction should be
reported as a non-cash investing activity.  Regarding the effect  of restatement on
previously filed financial statements, pleas e explain to us in further detail why the
correction to properly eliminate the non-cash activity for construction allowances which affected changes in accounts receivable and deferred construction
allowances in operating activities also had an effect on capital expenditures in
investing activities.  Also, it appe ars that your description of the non-
mathematical classification errors in your  response differs from the description

Mr. Timothy E. Kullman
Dick’s Sporting Goods, Inc. June 29, 2007
Page 2
contained in Form 8-K.  As requested in our initial comment, please consider
amending the filing to provide a more deta iled description of the facts underlying
the classification errors a nd your conclusion that prev iously issued financial
statements should not be relied upon.  Refer to Item 4.02(a)(2) of Form 8-K.

2. In future periodic filings please c onsider identifying and describing your
accounting policies in regard  to your sale-leaseback tr ansactions, EITF 97-10 and
your related cash flow pres entation.  Refer to paragraph 12 of APB 22.  To the
extent material, please also consider  providing the disclo sures required by
paragraphs 17 and 18 of SFAS 98.

As appropriate, please amend your filing and respond to these comments within
five business days or tell us when you will provide us with a response.  You may wish to provide us with marked copies of the amendm ent to expedite our review.  Please furnish
a cover letter that provides any requested in formation.  Detailed cover letters greatly
facilitate our review.  Please understand th at we may have additional comments after
reviewing your amendment and response to our comments.  Please submit your response
letter on EDGAR.

If you have any questions regarding these co mments, please direct them to me at
(202) 551-3336.  In my absence, you may di rect your questions to William Thompson,
Branch Chief, at (202) 551-3344.

Sincerely,

 Adam Phippen
Staff Accountant