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SEC Comment Letter 0000000000-25-003033 to GameStop Corp. (GME)

GameStop Corp.
Date: March 20, 2025 · CIK: 0001326380 · Accession: 0000000000-25-003033

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File numbers found in text: 001-32637

Date
March 20, 2025
Author
Division of
Form
UPLOAD
Company
GameStop Corp.

Letter

Re: GameStop Corp. Form 10-K for Fiscal Year Ended February 3, 2024 Response dated February 12, 2025 File No. 001-32637 Dear Ryan Cohen:

March 20, 2025

Ryan Cohen Chief Executive Officer GameStop Corp. 625 Westport Parkway Grapevine, TX 76051

We have reviewed your February 12, 2025 response to our comment letter and have the following comment.

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe the comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our January 29, 2025 letter.

Form 10-K for Fiscal Year Ended February 3, 2024 Our portfolio of securities may be concentrated in one or a few holdings, which may result in a single holding..., page 11

1. We note your response to prior comment 2, including your commitment to maintaining this risk factor in future filings. Please revise to disclose the role, if any, of the Investment Committee and/or the Board of Directors in specifically overseeing any investment risk as it relates to your Investment Policy and any decision to concentrate holdings. March 20, 2025 Page 2

Please contact Scott Stringer at 202-551-3272 or Joel Parker at 202-551-3651 if you have questions regarding comments on the financial statements and related matters. Please contact Alyssa Wall at 202-551-8106 or Cara Wirth at 202-551-7127 with any other questions.

Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
cc: Erica Hogan

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 20, 2025

Ryan Cohen
Chief Executive Officer
GameStop Corp.
625 Westport Parkway
Grapevine, TX 76051

 Re: GameStop Corp.
 Form 10-K for Fiscal Year Ended February 3, 2024
 Response dated February 12, 2025
 File No. 001-32637
Dear Ryan Cohen:

 We have reviewed your February 12, 2025 response to our comment letter
and have
the following comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe
the comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our January
29, 2025 letter.

Form 10-K for Fiscal Year Ended February 3, 2024
Our portfolio of securities may be concentrated in one or a few holdings, which
may result in
a single holding..., page 11

1. We note your response to prior comment 2, including your commitment to
 maintaining this risk factor in future filings. Please revise to
disclose the role, if any,
 of the Investment Committee and/or the Board of Directors in
specifically overseeing
 any investment risk as it relates to your Investment Policy and any
decision to
 concentrate holdings.
 March 20, 2025
Page 2

 Please contact Scott Stringer at 202-551-3272 or Joel Parker at
202-551-3651 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alyssa Wall at 202-551-8106 or Cara Wirth at 202-551-7127 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Erica Hogan
</TEXT>
</DOCUMENT>