SEC Comment Letter for GameStop Corp. (GME) (CIK 0001326380) (GME) — Jun 12, 2018
GameStop Corp. (GME) (CIK 0001326380)
Date: June 12, 2018 · CIK: 0001326380 · Accession: 0000000000-18-018025
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 June 11 , 2018 Robert A. Lloyd Chief Financial Officer GameStop Corp. 625 Westport Parkway Grapevine, TX 76051
Re: GameStop Corp. Form 10 -K for Fiscal Year Ended February 3 , 2018 Filed April 2, 2018 File No. 001 -32637
Dear Mr. Lloyd :
We have limited our review of your filing to the financial statements and related disclosures and 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 applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments.
Form 8 -K filed March 28, 2018
Exhibit 99.1
Non-GAAP Measures
1. We note you have presented the non-GAAP measure digital receipts and define this measure as the full amount paid by the customer for digital content at the time of sale and/or the value attributed to digital content when physical and digital products are sold combined. Please tell us in more detail what this measure represents, as this is unclear to us from the definition included in your earnings release, and revise future presentations of this measure to clarify this to your investors. Your response should clarify how this measure d iffers from your GAAP digital revenue and related GAAP deferred revenue. We may have further comments after reviewing your response.
Robert A. Lloyd GameStop Corp. June 11 , 2018 Page 2
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, no twithstanding any review, comments, action or absence of action by the staff.
You may contact M yra Moosariparambil , Staff Accountant, at (202) 551 -3796 or me at (202) 551 -3737 with any questions.
Sincerely,
/s/ Jennifer Thompson
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Mail Stop 3561 June 11 , 2018 Robert A. Lloyd Chief Financial Officer GameStop Corp. 625 Westport Parkway Grapevine, TX 76051 Re: GameStop Corp. Form 10 -K for Fiscal Year Ended February 3 , 2018 Filed April 2, 2018 File No. 001 -32637 Dear Mr. Lloyd : We have limited our review of your filing to the financial statements and related disclosures and 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 applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Form 8 -K filed March 28, 2018 Exhibit 99.1 Non-GAAP Measures 1. We note you have presented the non-GAAP measure digital receipts and define this measure as the full amount paid by the customer for digital content at the time of sale and/or the value attributed to digital content when physical and digital products are sold combined. Please tell us in more detail what this measure represents, as this is unclear to us from the definition included in your earnings release, and revise future presentations of this measure to clarify this to your investors. Your response should clarify how this measure d iffers from your GAAP digital revenue and related GAAP deferred revenue. We may have further comments after reviewing your response. Robert A. Lloyd GameStop Corp. June 11 , 2018 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, no twithstanding any review, comments, action or absence of action by the staff. You may contact M yra Moosariparambil , Staff Accountant, at (202) 551 -3796 or me at (202) 551 -3737 with any questions. Sincerely, /s/ Jennifer Thompson Jennifer Thompson Accounting Branch Chief Office of Consumer Products