SEC Comment Letter for GameStop Corp. (GME) (CIK 0001326380) (GME) — Nov 2, 2007
GameStop Corp. (GME) (CIK 0001326380)
Date: Nov. 2, 2007 · CIK: 0001326380 · Accession: 0000000000-07-053916
AI Filing Summary & Sentiment
Referenced dates: September 26, 2007
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-0404 DIVISION OF CORPORATION FINANCE Mail Stop 3561 November 2, 2007 Mr. David W. Carlson Executive Vice President and Chief Financial Officer GameStop Corp. 625 Westport Parkway Grapevine, Texas 76051 Re: GameStop Corp. Form 10-K for the Fiscal Year Ended February 3, 2007 Filed April 4, 2007 File No. 1-32637
Dear Mr. Carlson: We have reviewed the responses in your letter filed on October 11, 2007 and have the following additional comment. We welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Form 10-K for the Fiscal Year Ended February 3, 2007
Schedule II – Valuation and Qualifying Accounts, page 48 1. We have reviewed your response to prior comment 7 in our letter dated September 26, 2007 and have the following additional comments: • Please provide us with further information regarding your valuation of the acquired Electronics Boutique inventorie s. Provide us with a table that summarizes the estimated selling price of the inventories, the costs of disposal, and the reasonable profit allowance for your selling efforts. In helping us understand why the revalued inventory balance was less than the acquiree’s book value, please tell us in detail the nature and estimated
Mr. David W. Carlson GameStop Corp. November 2, 2007 Page 2
amounts of the items you included in costs of disposal and differentiate the amounts estimated for direct vs. indirect costs; • Please explain why you believe that the amount of the profit you expected to earn for the selling effort was reasonable; and • Provide us with a detailed explanation of how and when the amounts included in your allowance are written off and tell us if any amounts were written off against any account other than inventory in any of the fiscal years presented.
* * * * *
As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your response to our comment and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your response to our comment.
You may contact Yong Kim at (202) 551-3323 if you have any questions regarding these comments. In her absence, you may direct your questions to Andrew Blume at (202) 551-3254. Please contact me at (202) 551-3716 with any other questions.
S i n c e r e l y , William Choi B r a n c h C h i e f
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404
DIVISION OF
CORPORATION FINANCE
Mail Stop 3561
November 2, 2007
Mr. David W. Carlson Executive Vice President and Chief Financial Officer GameStop Corp. 625 Westport Parkway Grapevine, Texas 76051
Re: GameStop Corp.
Form 10-K for the Fiscal Year Ended February 3, 2007
Filed April 4, 2007 File No. 1-32637
Dear Mr. Carlson:
We have reviewed the responses in your letter filed on October 11, 2007 and have
the following additional comment. We welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Form 10-K for the Fiscal Year Ended February 3, 2007
Schedule II – Valuation and Qualifying Accounts, page 48
1. We have reviewed your response to prior comment 7 in our letter dated
September 26, 2007 and have the following additional comments:
• Please provide us with further information regarding your valuation of the
acquired Electronics Boutique inventorie s. Provide us with a table that
summarizes the estimated selling price of the inventories, the costs of disposal, and the reasonable profit allowance for your selling efforts. In helping us understand why the revalued inventory balance was less than the acquiree’s book value, please tell us in detail the nature and estimated
Mr. David W. Carlson
GameStop Corp. November 2, 2007 Page 2
amounts of the items you included in costs of disposal and differentiate the amounts estimated for direct vs. indirect costs;
• Please explain why you believe that the amount of the profit you expected to earn for the selling effort was reasonable; and
• Provide us with a detailed explanation of how and when the amounts included in your allowance are written off and tell us if any amounts were written off against any account other than inventory in any of the fiscal years presented.
* * * * *
As appropriate, please respond to this comment within 10 business days or tell us
when you will provide us with a response. Please furnish a letter that keys your response to our comment and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your response to our comment.
You may contact Yong Kim at (202) 551-3323 if you have any questions
regarding these comments. In her absence, you may direct your questions to Andrew Blume at (202) 551-3254. Please contact me at (202) 551-3716 with any other questions.
S i n c e r e l y , William Choi B r a n c h C h i e f