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SEC Company Response from DICK'S SPORTING GOODS, INC. (DKS) (CIK 0001089063) (DKS) — Jun 21, 2011

DICK'S SPORTING GOODS, INC. (DKS) (CIK 0001089063)
Date: June 21, 2011 · CIK: 0001089063 · Accession: 0000950123-11-060548

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File numbers found in text: 001-31463

Date
June 21, 2011
Author
/s/ Timothy E. Kullman
Form
CORRESP
Company
DICK'S SPORTING GOODS, INC. (DKS) (CIK 0001089063)

Letter

Via Edgar Division of Corporation Finance Securities and Exchange Commission Dick’s Sporting Goods, Inc. Form 10-K for the Fiscal Year Ended January 29, 2011 Filed March 18, 2011 File No. 001-31463

Dear Mr. Alper:

This letter is being provided at your request by Dick’s Sporting Goods, Inc. (the “Company”) in connection with correspondence filed on the Company’s behalf on June 17, 2011, in which the Company agreed, in response to a comment orally communicated by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), to re-file the Company’s Second Amended and Restated Credit Agreement dated as of July 28, 2004, as then amended, and to include all corresponding schedules and exhibits, with the Company’s next quarterly report filed on Form 10-Q.

As requested by the Staff, the Company hereby acknowledges the following:

•

The Company is responsible for the adequacy and accuracy of the disclosures in its filings with the Commission;

•

Staff comments or changes to disclosures in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and

•

The Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If you have any questions, please do not hesitate to contact me at (724) 273-3229.

Very truly yours,
/s/ Timothy E. Kullman

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CORRESP
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corresp

[Dick’s Sporting Goods letterhead]

June 21, 2011

Via Edgar

Division of Corporation Finance

Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549-0503

Attn.: Ronald Alper

    Re:

    Dick’s Sporting Goods, Inc.

Form 10-K for the Fiscal Year Ended January 29, 2011

Filed March 18, 2011

File No. 001-31463

Dear Mr. Alper:

This letter is being provided at your request by Dick’s Sporting Goods, Inc. (the “Company”) in
connection with correspondence filed on the Company’s behalf on June 17, 2011, in which the Company
agreed, in response to a comment orally communicated by the staff (the “Staff”) of the Securities
and Exchange Commission (the “Commission”), to re-file the Company’s Second Amended and Restated
Credit Agreement dated as of July 28, 2004, as then amended, and to include all corresponding
schedules and exhibits, with the Company’s next quarterly report filed on Form 10-Q.

As requested by the Staff, the Company hereby acknowledges the following:

    •

    The Company is responsible for the adequacy and accuracy of the disclosures in its
filings with the Commission;

    •

    Staff comments or changes to disclosures in response to Staff comments do not foreclose
the Commission from taking any action with respect to the filings; and

    •

    The Company may not assert Staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

If you have any questions, please do not hesitate to contact me at (724) 273-3229.

Very truly yours,

    /s/  Timothy E. Kullman

    Timothy E. Kullman

    Executive Vice President- Finance,

Administration and Chief Financial Officer