SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3561

       DIVISION OF
CORPORATION FINANCE

    Mail Stop 3561
June 2, 2010
  Mr. Timothy E. Kullman Executive Vice President and Chief Financial Officer Dick’s Sporting Goods, Inc. 345 Court Street Coraopolis, Pennsylvania 15108
Re: Dick’s Sporting Goods, Inc.
Form 10-K for the Fiscal Year Ended January 30, 2010 Filed March 18, 2010 Form 8-K Filed March 9, 2010 File No. 1-31463
 Dear Mr. Kullman:
We have reviewed your filings and have the following comments.  We have limited our
review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your document.  Pleas e provide a written resp onse to our comments.
Please be as detailed as necessa ry in your explanation.  In some  of our comments, we may ask
you to provide us with information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.
  Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filings.  We look forward to working with  you in these respects.  We welcome any
questions you may have about our comments or any other aspect of our review.  Feel free to call
us at the telephone numbers listed  at the end of this letter.

Mr. Timothy E. Kullman
Dick’s Sporting Goods, Inc.
June 2, 2010 Page 2

Form 10-K for the Fiscal Year Ended January 30, 2010
 Financial Statements, page 45

General

1. We note your disclosure in MD&A that you amended your e-commerce agreement and
began recording e-commerce revenue on a gros s basis compared to your prior recording
of these revenues on a net basis pursuant to  FASB ASC 605-45.  We have the following
comments:

• Please clarify whether this e-commerce agre ement is the same agreement with GSI
discussed in footnote 13 on page  69.  If so, please explain the terms of the agreement,
including the compensation arrangement with GSI for their services and how it relates
to the royalty arrangement.
• Please tell us the terms of the amendment that resulted in the change to recording
revenues gross from recording them net.  In  doing so, please addre ss each indicator in
ASC 605-45 to support your position that that gross reporting is now appropriate.

• Please tell us and disclose in MD&A the amount of revenue from e-commerce sales.
We note your discussion in resu lts of operations that net sales increased due to the
addition of e-commerce sales; however, you do not quantify the amount of e-
commerce sales.  We also note that you a ppear to quantify sales from e-commerce in
your quarterly earnings conference calls, and be lieve this is important information to
also provide to your investor s within your MD&A narrative.
 Consolidated Statements of Operations, page 47

 2. We note on page 8 that you provide support se rvices, such as golf services, bicycle
maintenance and repairs, tennis racquet and l acrosse stick stringing, ice skate sharpening
and assembly of fitness equipment.  Pleas e quantify for us your revenues from these
support services for each year  included in your filing.  To  the extent that your support
service revenues exceed ten pe rcent of your total revenues, please separately present
service revenues on the face of your income stat ement.  Refer to Rule 5-03 of Regulation
S-X.  Notwithstanding the preceding, please expand your revenue recognition policy for these support service revenues.
 Notes to Consolidated Financial Statements, page 52

 Segment Information, page 56

 3. We note that you aggregate your operating segm ents into one reportable segment due to
the economic characteristics of the store formats, the similar nature of the products sold,

Mr. Timothy E. Kullman
Dick’s Sporting Goods, Inc.
June 2, 2010 Page 3

the type of customer and the method of distri bution.  Please explain to us what is meant
by “economic characteristics of the store format s” and why that supports aggregation.
Also, please tell us in sufficient detail how you identified your operating segments and
how you determined that your operating segments  have similar economic characteristics,
including similar long-term average gross marg ins.  In doing so, provide us with your
analysis of the similar economic characteristics of your Dick ’s Sporting Goods stores and
your Golf Galaxy stores to support aggregating these stores into one reportable segment.
Your response should also address the fact that you separately discuss the Dick’s Sporting Goods stores and the Golf Galaxy stor es in your quarterly earnings conference
calls, and provide your analysis of whether the differences in these businesses that
warrant separate discussion in your earnings calls support presenting these chains as separate reportable segments.  Refer to ASC 280-10-50.
 Schedule II – Valuation and Qualifying Accounts, page 74

 4. We note on page 55 that that you record a pr ovision for anticipated merchandise returns
through a reduction of sales and cost of sales.  Please provide us with a rollforward of this
provision for each year included in your fili ng.  Please also tell us how you considered
including the activity in your merchandise returns and allowance account in this schedule or within the notes to the financial stat ements.  Refer to Rules 5-04 and 12-09 of
Regulation S-X for guidance.
 Form 8-K Filed March 9, 2010

 5. We note your presentation of EBITDA, and we also note that you define EBITDA in the
first paragraph under the heading “Non-GAAP Fi nancial Measures” as earnings before
interest, taxes and depreciati on; however, your EBITDA reconciliation presents earnings
before interest, taxes, de preciation and amortization, me rger integration costs,
impairment of goodwill and other intangibles, impa irment of store assets and gain on sale
of asset.  Please revise future filings to en sure that the reconciliat ion of this measure and
its description within your narrative are consistent.  Also, given that EBITDA is widely
established as earnings before  interest, taxes, depreciati on and amortization, and you do
not define it as such, please rename your measure.  See Question 103.01 of our
Compliance and Disclosure Interpretations concerning Non-GAAP Financial Measures,
available on our website at www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm
.
 6. We note your reconciliation of non-GAAP net in come and earnings per share.  Please tell
us, and disclose in future filings, how you calcu lated the tax effect of the elimination of
merger and integration costs.  See Ques tion 102.11 of our Compliance and Disclosure
Interpretations concerning Non-GAAP Financial Measures, availabl e on our website at
www.sec.gov/divisions/corpfin /guidance/nongaapinterp.htm
.

*      *      *      *      *

Mr. Timothy E. Kullman
Dick’s Sporting Goods, Inc. June 2, 2010 Page 4

Please respond to these comments within 10 business days or tell us when you will
provide us with a response.  Please furnish a letter that keys your respon ses to our comments and
provides any requested information.  Detailed letters greatly facilitate  our review.  Please
understand that we may have additional comm ents after reviewing your response to our
comments.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filings to be certain that the filings include all information required under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision.  Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.
In connection with responding to our comment s, please provide, in writing, a statement
from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
 • the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the sta ff of the Division of Corporati on Finance in our review of your
filings or in response to our  comments on your filings.

  You may contact Yong Kim at (202) 551-3323 if you have any questions regarding these
comments.  Please contact me at (202) 551-3737 with any other questions.

         S i n c e r e l y ,

          Jennifer Thompson
         B r a n c h  C h i e f