SecProbe.io

September 29, 2014

Via E -mail
Mr. J. Paul Raines
Chief Executive Officer
GameStop Corp.
625 Westport Parkway
Grapevine, Texas  76051

Re: GameStop Corp.
 Form 10-K for Fiscal Year Ended February 1, 2014
Filed April 2, 2014
File No. 001 -32637

Dear Mr. Raines :

We have reviewed your filing 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 ot her portions of your documents.  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 respon se.

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 Fiscal Year Ended February 1, 2014

Financial Statements, Page F -1

Reports of I ndependent Registered Public Accounting Firms, pages F -2 and F -3

1. We note the revisions to your previously issued fiscal 2012 and 2011 financial statements
included herein.  We note that the report of BDO USA, LLP (“BDO”) on your prior
period financial sta tements continues to be dated April 3, 2013 which is the date of their
original report.  We also note that the report of Deloitte & Touche, LLP (“Deloitte &
Touche”) on your fiscal 2013 financial statements does not indicate that they audited the
adjustmen ts to the prior period financial statements.  It appears that one of these two
accounting firms should express an opinion that covers the adjustments to the previously

Mr. J. Paul Raines
GameStop Corp.
September 29, 2014
Page 2

 issued financial statements.  Please refer to AU -C Sections 700 and 708 and tell us how
you, BDO and Deloitte & Touche considered this guidance.

Note 1. Nature of Operations and Summary of Significant Accounting Policies, page F -9

Basis of Presentation and Consolidation, page F -9

2. We note your disclosure that you  revised the presentation of  outstanding checks in your
prior period financial statements.  You state that you previously reduced cash and
liabilities when checks were presented for payment and cleared your bank accounts, and
currently,  as of February 1, 2014, you reduce cash and lia bilities when the checks are
released for payment.  Please tell us whether your revised presentation of outstanding
checks represents a change in accounting principle or an error pursuant to ASC 250 and
provide the basis for your conclusion.   If you conclu de that this was an error, please
address the following:

 Please tell us why you did not indicate that the previously issued financial statements
have been restated to correct an error.  Refer to ASC 250 -10-50-7.

 Please tell us how the error was identified.

 Please tell us how you considered the error when concluding on the effectiveness of
your disclosure controls and procedures and internal controls over financial reporting.

 Please tell us what consideration you gave to filing an Item 4.02 Form  8-K regarding
non-reliance on previously issued financial statements.

4. Vendor Arrangements, page F -17

3. We note that in fiscal 2013  you reclassified cert ain costs related to cash consideration
received from your vendors from selling, general and administrative expenses to cost of
sales  to align those funds with the specific products sold.  We note that all vendor
allowances were recorded as a reduction to cost of sales in fiscal 2013, while in fiscal
2012 and 2011, vendor allowances were recorded as both a reduction to cost of sales and
selling, general and administrative expense.  Please tell us why these costs were
reclassified in fiscal 2013 and whether this represents a change in accounting principle,
change in accounting estimate or an error p ursuant to ASC 250 and provide the basis for
your conclusion.  Please also tell us how you accounted for vendor allowances in
accordance with ASC 605 -50-25 and 605 -50-45 for all periods presented.  Furthermore,
please explain the circumstances that changed  from fiscal 2012 to fiscal 2013 that
warranted the reclassification and why you do not believe prior periods should be
reclassified.

Mr. J. Paul Raines
GameStop Corp.
September 29, 2014
Page 3

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that  the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the ac curacy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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 federal securities laws of the United States.

You may contact Sondra Snyder, Staff Accountant , at (202) 551 -3332  or Yong Kim,
Staff Accountant, at (202) 551 -3323 if you have questions regarding our comments .  Please
contact me at (202) 551 -3737  with any other questions.

Sincerely,

 /s/ Jennifer Thompson

Jennifer Thompson
Accounting Branch Chief