SEC Comment Letter for GameStop Corp. (GME) (CIK 0001326380) (GME) — Sep 29, 2015
GameStop Corp. (GME) (CIK 0001326380)
Date: Sept. 29, 2015 · CIK: 0001326380 · Accession: 0000000000-15-047677
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 September 2 8, 2015 J. Paul Raines Chief Executive Officer GameStop Corp. 625 Westport Parkway Grapevine, Texas 76051
Re: GameStop Corp. Form 10-K for Fiscal Year Ended January 31, 2015 Filed March 30, 2015 File No. 001 -32637
Dear Mr. Raines :
We have reviewed your filing an d have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances , please tell us why in your r esponse.
After reviewing your response to this comment, we may have additional comments.
Consolidated Financial Statements
Note 10. Debt, page F -21
1. We note your disclosure that the Indenture for your $350.0 million Senior Notes contains covenants w hich place certain restrictions on you and your subsidiaries, including restrictions on the payment of dividends and distributions. Please disclose the amount of retained earnings or net income restricted or free of restrictions. Please refer to Rule 4 - 08(e)(1) of Regulation S -X. In addition, please tell us the amount of restricted net assets of consolidated subsidiaries as of January 31, 2015 and your consideration of disclosing the information required by Rule 4 -08(e)(3) and providing the schedule requ ired by Rule 12-04 of Regulation S -X.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exc hange Act rules require. Since the company and its management are
J. Paul Raines GameStop Corp. September 2 8, 2015 Page 2
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comment, 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 S ondra Snyder, Staff Accountant at (202) 551 -3332 or Anthony Watson, Staff Accountant at (202) 551-3318 , or me at (202) 551 -3737 if you have any questions.
Sincerely,
/s/ Jennifer Thompson
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Mail Stop 3561 September 2 8, 2015 J. Paul Raines Chief Executive Officer GameStop Corp. 625 Westport Parkway Grapevine, Texas 76051 Re: GameStop Corp. Form 10-K for Fiscal Year Ended January 31, 2015 Filed March 30, 2015 File No. 001 -32637 Dear Mr. Raines : We have reviewed your filing an d have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances , please tell us why in your r esponse. After reviewing your response to this comment, we may have additional comments. Consolidated Financial Statements Note 10. Debt, page F -21 1. We note your disclosure that the Indenture for your $350.0 million Senior Notes contains covenants w hich place certain restrictions on you and your subsidiaries, including restrictions on the payment of dividends and distributions. Please disclose the amount of retained earnings or net income restricted or free of restrictions. Please refer to Rule 4 - 08(e)(1) of Regulation S -X. In addition, please tell us the amount of restricted net assets of consolidated subsidiaries as of January 31, 2015 and your consideration of disclosing the information required by Rule 4 -08(e)(3) and providing the schedule requ ired by Rule 12-04 of Regulation S -X. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exc hange Act rules require. Since the company and its management are J. Paul Raines GameStop Corp. September 2 8, 2015 Page 2 in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comment, 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 S ondra Snyder, Staff Accountant at (202) 551 -3332 or Anthony Watson, Staff Accountant at (202) 551-3318 , or me at (202) 551 -3737 if you have any questions. Sincerely, /s/ Jennifer Thompson Jennifer Thompson Accounting Branch Chief Office of Consumer Products