SEC Comment Letter for GameStop Corp. (GME) (CIK 0001326380) (GME) — Oct 2, 2013
GameStop Corp. (GME) (CIK 0001326380)
Date: Oct. 2, 2013 · CIK: 0001326380 · Accession: 0000000000-13-054353
AI Filing Summary & Sentiment
File numbers found in text: 001-32637
Referenced dates: August 16, 2013, August 16, 2013
Letter
October 2 , 2013 Via E -mail J. Paul Raines Chief Executive Officer GameStop Corp. 625 Westport Parkway Grapevine, TX 76051
Re: GameStop Corp. Form 10-K for the year ended February 2, 2013 Filed April 3, 2013 File No. 001-32637
Dear Mr. Raines :
We have reviewed your response dated September 16, 2013 and have the following additional comment s. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.
Form 10 -K for the year ended February 2, 2013
Consolidated Financial Statements, page F -1
Note 1. Summary of Significant Accounting Policies, page F-9
Loyalty Expenses, page F -13
1. We note you r response to comment 3 from our letter dated August 16, 2013. Please explain the accounting for your loyalty program in more detail , including providing illustrative journal entries that you record at the ti me of the sale of merchandise and at the time of point redemption.
J. Paul Raines GameStop Corp. October 2 , 2013 Page 2
Note 16. Significant Products, page F -36
2. We note your response to comment 6 from our letter dated August 16, 2013 . Although your “Other” product category account ed for only 13 -17% of your revenues for the fiscal years presented , we note that it represented approximately 34 -40% of your overall gross profit. Please quantify for us the impact on revenues and gross profit for each “Other” sub-product disclosed on page 37 and referenced in our prior comment . To the extent any sub -product materially contributes to your gross profit , please provide additional disclosures in your filing to enable investors to see the company through the eyes of management or tell us why yo u believe such information would not be useful to investors.
You may contact Lisa Sellars, Staff accountant , at (202) 551 -3348 or Andrew Blume, Staff Accountant , at (202) 551 -3254 if you have questions regarding comments on the financial statements and related matters. You may contact me at (202) 551 -3737 with any other questions.
Sincerely,
/s/ Jennifer Thompson
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October 2 , 2013 Via E -mail J. Paul Raines Chief Executive Officer GameStop Corp. 625 Westport Parkway Grapevine, TX 76051 Re: GameStop Corp. Form 10-K for the year ended February 2, 2013 Filed April 3, 2013 File No. 001-32637 Dear Mr. Raines : We have reviewed your response dated September 16, 2013 and have the following additional comment s. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 10 -K for the year ended February 2, 2013 Consolidated Financial Statements, page F -1 Note 1. Summary of Significant Accounting Policies, page F-9 Loyalty Expenses, page F -13 1. We note you r response to comment 3 from our letter dated August 16, 2013. Please explain the accounting for your loyalty program in more detail , including providing illustrative journal entries that you record at the ti me of the sale of merchandise and at the time of point redemption. J. Paul Raines GameStop Corp. October 2 , 2013 Page 2 Note 16. Significant Products, page F -36 2. We note your response to comment 6 from our letter dated August 16, 2013 . Although your “Other” product category account ed for only 13 -17% of your revenues for the fiscal years presented , we note that it represented approximately 34 -40% of your overall gross profit. Please quantify for us the impact on revenues and gross profit for each “Other” sub-product disclosed on page 37 and referenced in our prior comment . To the extent any sub -product materially contributes to your gross profit , please provide additional disclosures in your filing to enable investors to see the company through the eyes of management or tell us why yo u believe such information would not be useful to investors. You may contact Lisa Sellars, Staff accountant , at (202) 551 -3348 or Andrew Blume, Staff Accountant , at (202) 551 -3254 if you have questions regarding comments on the financial statements and related matters. You may contact me at (202) 551 -3737 with any other questions. Sincerely, /s/ Jennifer Thompson Jennifer Thompson Accounting Branch Chief