SEC Comment Letter for GameStop Corp. (GME) (CIK 0001326380) (GME) — Nov 8, 2013
GameStop Corp. (GME) (CIK 0001326380)
Date: Nov. 8, 2013 · CIK: 0001326380 · Accession: 0000000000-13-061597
AI Filing Summary & Sentiment
File numbers found in text: 001-32637
Letter
November 8, 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 October 23 , 2013 and have the following additional comment . In our comment , 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 comment applies 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 this comment , 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 your response to comment 1 from our letter date d October 2, 2013 and are still unclear why you classify the costs of your loyalty program as selling, general and administrative expenses. Considering the cost of inventory is typically relieved through costs of sales, tell us why it is appropriate to cl assify the cost of free or discounted products earned by your customers outside of cost of sales.
J. Paul Raines GameStop Corp. November 8, 2013 Page 2
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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November 8, 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 October 23 , 2013 and have the following additional comment . In our comment , 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 comment applies 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 this comment , 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 your response to comment 1 from our letter date d October 2, 2013 and are still unclear why you classify the costs of your loyalty program as selling, general and administrative expenses. Considering the cost of inventory is typically relieved through costs of sales, tell us why it is appropriate to cl assify the cost of free or discounted products earned by your customers outside of cost of sales. J. Paul Raines GameStop Corp. November 8, 2013 Page 2 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