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UPLOAD Filing

GameStop Corp.
Date: May 29, 2025 · CIK: 0001326380 · Accession: 0000000000-25-005652

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File numbers found in text: 001-32637

Date
May 29, 2025
Author
Division of
Form
UPLOAD
Company
GameStop Corp.

Letter

Re: GameStop Corp. Form 10-K for Fiscal Year Ended February 1, 2025 Response dated March 25, 2025 File No. 001-32637 Dear Ryan Cohen:

May 29, 2025

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

We have reviewed your filing 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 a 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.

Form 10-K for the Fiscal Year Ended February 1, 2025 Item 1A. Risk Factors Risks Related to Our Investment Policy and Investment Portfolio If we are deemed to be an investment company under the Investment Company Act ..., page 7

1. We note your risk factor that you may be deemed to be an investment company under the Investment Company Act of 1940. Please revise to include the specific facts and characteristics of your business that you considered in this analysis, including your levels of cash and cash equivalents as well as the implementation and execution of your Investment Policy. Further, we note your statements that if you are regulated as an investment company under the Investment Company Act of 1940, your activities may be restricted and burdensome requirements may be imposed upon you. Please revise to elaborate on such restrictions and requirements, including a description of your plan of operations under such, and the potential negative effects on your holdings and the market value of your Class A Common Stock. May 29, 2025 Page 2

We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

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>
 May 29, 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 1, 2025
 Response dated March 25, 2025
 File No. 001-32637
Dear Ryan Cohen:

 We have reviewed your filing 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 a
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.

Form 10-K for the Fiscal Year Ended February 1, 2025
Item 1A. Risk Factors
Risks Related to Our Investment Policy and Investment Portfolio
If we are deemed to be an investment company under the Investment Company Act
..., page 7

1. We note your risk factor that you may be deemed to be an investment
company under
 the Investment Company Act of 1940. Please revise to include the
specific facts and
 characteristics of your business that you considered in this analysis,
including your
 levels of cash and cash equivalents as well as the implementation and
execution of
 your Investment Policy. Further, we note your statements that if you are
regulated as
 an investment company under the Investment Company Act of 1940, your
activities
 may be restricted and burdensome requirements may be imposed upon you.
Please
 revise to elaborate on such restrictions and requirements, including a
description of
 your plan of operations under such, and the potential negative effects
on your holdings
 and the market value of your Class A Common Stock.
 May 29, 2025
Page 2

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 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>