SecProbe.io

Mail Stop 3561
July 19, 2016

Mr. Robert A. Lloyd
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 January 30, 2016
Filed March 28 , 2016
File No. 1 -32637

Dear Mr. Lloyd :

We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.

Please respond to these comments  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
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Site Selection and Location, page 8

1. Please co nsider presenting a rollfoward of the number of stores by retail brand with
separate presentation of number of stores closed and opened for the most recent fiscal
year.  With the continued growth of your AT&T, Cricket, Simply Mac, Zing Pop Culture
and Thin kGeek stores, we believe it would beneficial to a reader to see the number of
stores by brand.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Consolidated Results of Operations, page 32

2. We note your presentation of  net sales and gross profit by significant product category
here and in your segment disclosures.  We further note that your “mobile and consumer
electronics” product category consists mainly of your Technology Brand segment
through Spring Mobile managed A T&T and Cricket branded stores and Simply Mac

Mr. Robert A. Lloyd
Gamestop Corp.
  July 19 , 2016
Page 2

 stores, but also includes the sale of headphones, accessories and pre -owned smart phones
in your Video Game Brand stores.  Given your continued growth of these brands and the
vastly different gross margins, ple ase consider separately presenting your Spring Mobile
managed AT&T and Cricket stores and your Simply Mac stores as two distinct product
categories.  We believe investors would benefit from separate presentation to better
appreciate the growth and  gross margins each delivers.  If Spring Mobile and Simply
Mac will each be presented separately, please tell us the category in which the mobile and
consumer electronics sold in your Video Game Brand stores will be presented.

Financial Statements

Consolidated  Statement of Operations, page F -4

3. We note your description on page 3 that your AT&T branded stores sell both pre and
post-paid AT&T services, DirecTV service and wireless products.  We also note that you
earn commission revenue on certain digital product s for which you do not take physical
possession of or title to inventory.  Therefore, it appears to us that you may have both
sales of tangible products and revenues from services.  Please tell us how you consider ed
separately presenting net sales from tangible products and revenues from services  on the
face of your income statement.  Refer to Rule 5 -03b of Regulation S -X.

Notes to Consolidated Financial Statements

1. Nature of Operations and Summary of Significant Accounting Policies

Revenue Recognition, page F -9

4. We note that you earn commissions from the sale of digital products and from the
activation of new wireless customers and activation of enhanced or upgraded features on
existing wireless customer plans in your Spring Mobile business as an AT&T authorized
dealer.  We also note that you determined that you are not the primary obligor on the
underlying AT&T wireless services contracts.  Please provide us with your gross versus
net analysis for revenue recognition related to your digital product sales and your AT&T
service contracts.  In doing so, please address each of the indicators in ASC 605 -45-45.
Please also clarify if all sales of digital products are recorded on a net basis.
Furthermore, please  tell us the different types of prod ucts and services sold as an AT&T
authorized dealer and whether each of those revenues are recorded gross or net.

Mr. Robert A. Lloyd
Gamestop Corp.
  July 19 , 2016
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 inc ludes 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 accuracy
and adeq uacy 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  Yong  Kim, Staff  Accountant,  at (202)  551-3323  or Lisa Sellars ,
Staff  Accountant,  at (202) 551-3348  if you have  questions regarding  comments on the financial
statements  and related  matters.   Please contact  me at (202)  551-3737  with any other  questions.

Sincerely,

 /s/ Jennifer Thompson

Jennifer Thompson
Accounting Branch Chief
Officer of Consumer Products