GMEGameStop

Please consider 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 ThinkGeek stores, we believe it would beneficial to a reader to see the number of stores by brand.

In future annual filings, we will include a rollforward of the number of stores by retail type with a separate presentation of the number of stores closed and opened in a tabular format for the most recent fiscal year. We will aggregate our Video Game stores, including GameStop, EB Games, and Micromania as they are similar store formats; will combine Zing Pop Culture and ThinkGeek stores as “Collectibles stores” since these two brands are also very similar store formats; and we will reflect AT&T, Cricket and Simply Mac brands separately.

A sample of the Company’s proposed disclosure for the

Rest of the answer

fiscal year ending January 30, 2016 is set forth below.

January 31, 2015

Opened/Acquired

Closed

January 30, 2016

Video Game Stores

6,202

(210

)

6,046

Collectibles Stores

Total Video Game Brands

6,206

6,081

Spring Mobile

361

535

(6

890

Cricket

(10

Simply Mac

Total Technology Brands

484

568

(16

1,036

Total Stores

6,690

653

(226

Read in the reply ↗

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 AT&T and Cricket branded stores and Simply Mac stores, but also includes the sale of headphones, accessories and pre-owned smart phones

Rest of the question

in your Video Game Brand stores. Given your continued growth of these brands and the vastly different gross margins, please 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.

As noted in our Form 10-K for the fiscal year ended January 30, 2016, and as noted in the Staff’s comment above, the majority of our “mobile and consumer electronics” product category has consisted of our Technology Brands segment since the acquisitions of our Spring Mobile and Simply Mac businesses in 2013.

Rest of the answer

For the fiscal years ended January 30, 2016, January 31, 2015, and February 1, 2014, our Technology Brands segment made up 81.8%, 63.3% and 20.7% of mobile and consumer electronics net sales, respectively.

Given the continued growth of our Technology Brands business, we will reflect our net sales and gross profit for our Spring Mobile, Cricket and Simply Mac businesses together as a separate Technology Brands product category beginning with the quarter ending October 29, 2016. We believe that the combined presentation of all three brands within the Technology Brands category is the most meaningful disclosure for investors because our Simply Mac business is not a material part of our operations and has not been a significant component of the growth in our Technology Brands business. For each of the fiscal years ending January 30, 2016 and January 31, 2015, our Simply Mac business represented less than 2% of our total company net sales and only 1% of our total company gross profit, and we do not expect the Simply Mac contribution to our business to significantly increase in the near future.

Additionally, in our future filings, we will include the revenue from mobile and consumer electronics products sold in our Video Game Brands stores under our “other” products category due to immateriality. For the fiscal years ending January 30, 2016, January 31, 2015, and February 1, 2014, mobile and consumer electronics revenue in our Video Game Brands stores represented 1%, 2% and 2% of our total company net sales, respectively.

Read in the reply ↗

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 products 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.

Rest of the question

Please tell us how you considered 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

We respectfully acknowledge the Staff’s comment, and advise the Staff that we examined the guidance set forth in Rule 5-03(b) of Regulation S-X, and determined that the Company’s current aggregate revenue presentation is appropriate. The Company derives its revenues primarily from sales of tangible products, including new and pre-owned video game hardware and software, video game accessories, collectible merchandise and mobile and consumer electronics products.

Rest of the answer

We determined that these revenue streams are aligned with the guidance of Rule 5-03(b)(1)(a), which requires the presentation of “net sales of tangible products.”

The Company also derives revenues from the sale of “services” per Rule 5-03(b)(1)(d), such as product warranties and from “other” classes of revenue per Rule 5-03(b)(1)(e), such as commission revenues generated from the sale of digital products, the activation of new wireless plans, the activation of enhanced or upgraded features on existing wireless plans and the activation of other services provided by AT&T. However, revenues derived from all sources of revenue other than the sales of tangible products comprised less than 7% of the Company’s revenues in the fiscal years ending January 30, 2016, January 31, 2015, and February 1, 2014. As such, in accordance with Rule 5-03(b)(1), this service revenue and other revenue has not been presented separately on the Company’s statements of operations. To the extent the percentage of our service revenue or other revenue exceeds 10% of total revenue, we will modify the presentation.

Notes to Consolidated Financial Statements

1. Nature of Operations and Summary of Significant Accounting Policies

Read in the reply ↗

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.

Rest of the question

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 products and services sold as an AT&T authorized dealer and whether each of those revenues are recorded gross or net.

Gross versus net analysis

As noted in our Form 10-K for the fiscal year ended January 30, 2016, and as noted in the Staff’s comment above, the Company earns commission revenues from the sale of digital products, the activation of new wireless plans and the activation of enhanced or upgraded features on existing wireless plans. The Company has carefully considered the guidance in ASC 605-45-45 in its decision on whether to recognize these revenues on a gross or net basis.

Rest of the answer

The specific indicators that we considered for each of these sales categories are as follows:

Indicator per

ASC 605-45-45

Sale of Digital Products

Activation of Wireless Plans

Comments:

The Company Is the Primary Obligor

Net

In both the sale of digital products and the activation of new wireless plans, the Company is not the primary obligor. For the digital products we sell, our vendors have the ultimate responsibility for delivering the digital products and are responsible for the acceptability of those digital products. For activations of new wireless plans, AT&T has the responsibility for providing the wireless services to the customer and is responsible for the acceptability of the wireless services.

The Company Has General Inventory Risk

The Company does not take inventory risk in either the sale of digital products or the sale of wireless service plans. For most digital products we sell, the Company never takes title to the digital product. The digital product is activated at the time of sale which enables the customer to access the digital product delivered by the publisher or service provider. For wireless service plans, the Company does not purchase the wireless service plans from the service provider for resale to our customers.

The Company Has Latitude in Establishing Price

For the digital products we sell, we have limited ability to establish sales prices. For wireless service plans, we do not have the ability to set price.

The Company Changes the Product or Performs Part of the Service

The Company does not change any part of the digital products we sell nor do we perform any part of the wireless services purchased by our customers. Both the digital products and wireless services are provided to our customers in their original form directly from the digital product vendors and AT&T, respectively.

The Company Has Discretion in Supplier Selection

The Company does not have supplier discretion in either the digital products we provide or the wireless services plans we offer.

The Company Is Involved in the Determination of Product or Service Specifications

The Company is not involved in the determination of product or service specifications for either the digital products we sell or the wireless service plans we offer.

The Company Has Physical Loss Inventory Risk

The risk of inventory loss is not applicable to the digital products or the wireless service plans we sell. Both the digital products and the wireless service plans we sell are activated immediately at the point of sale.

The Company Has Credit Risk

For sales of digital products, the Company does not have credit risk since the full amount of payment is collected at the point of sale. For sales of wireless service plans, the Company does not have credit risk as the customer is billed directly by AT&T for wireless services. In the event of certain wireless service plan or feature cancellations, the Company is only responsible for refunding the commission we earned in the initial sale transactions.

Based on a comprehensive review of all the indicators above, as defined in ASC 605-45-45, we respectfully submit to the Staff that the Company appropriately determined that we are acting as an agent in both our sale of digital products and wireless service plans and as such have appropriately recorded revenues for these products and services on a net basis.

As noted in our Form 10-K for the fiscal year ended January 30, 2016, we do not record all digital product sales on a net basis. For the fiscal year ended January 30, 2016, less than 10% of our digital sales, or less than 1% of total sales, were recorded on a gross basis. We recognize certain digital sales on a gross basis where we are required to pre-purchase unique digital product activation codes from game developers prior to the sale to our customers and bare the risk of loss if we do not sell those codes.

Types of products and services sold as an AT&T authorized dealer

As noted in our Form 10-K for the fiscal year ended January 30, 2016, we sell several different products and services in our AT&T authorized stores. In general, the products and services we sell in these stores and the revenue recognition treatment are outlined below.

Wireless service plans — We sell AT&T wireless service plans for mobile phones and tablets. These sales are recognized on a net basis as described above.

Other services — We sell other services offered by AT&T including digital television subscriptions (DIRECTV) and home automation and security services plans and equipment (AT&T Digital Life). We recognize these sales on a net basis. It should be noted that the ASC 605-45-45 gross versus net analysis for these services is similar to the gross versus net analysis for wireless service plans discussed previously.

Products (including wireless devices and accessories) — We sell wireless devices (phones and tablets) and related accessories. These sales are recognized on a gross basis with the exception of wireless devices sold through AT&T’s NEXT wireless service plan. For the fiscal year ended January 30, 2016, over 95% of wireless devices we activated in our AT&T authorized dealer stores were sold under AT&T’s NEXT plan. This plan allows the customer to activate a wireless service plan for a period of 24 or 30 months and lease a wireless device for the same period from AT&T. In these transactions, we deliver the device to the customer on behalf of AT&T, and AT&T reimburses us for the cost of the device. We determined that these transactions are not sales of consignment inventory, since we take title to and assume risk of ownership of inventory at the time we purchase the devices from AT&T. We do not record a product sale for these transactions.

Warranties — We sell mobile device warranties and protection plans. These sales are recognized on a net basis since we are selling these warranty and protection plans for a commission on behalf of AT&T who is responsible for performing under these warranties and protection plans.

We hereby acknowledge that:

• we are responsible for the adequacy and accuracy of the disclosure in the filing;

Staff comments or changes in disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and we 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.

Read in the reply ↗

We note your response to comment 3 from our letter dated August 16, 2013. Please explain the accounting for your loyalty program in more detail, including providing illustrative journal entries that you record at the time of the sale of merchandise and at the time of point redemption.

Background

The PowerUp Rewards loyalty program allows enrolled members to earn points on purchases in our stores and on some of our Web sites. Members generally earn between 10 and 22 points for each dollar spent on GameStop merchandise which can be redeemed for rewards that include promotional items and other merchandise such as gift cards, subscriptions to on-line game access and points cards for gaming platforms as well as in-store and on-line discounts.

Rest of the answer

The estimated cost of a point earned by a member is based on our most recent history of costs incurred to fulfill point redemptions and consideration of the rewards offered to our members in the rewards catalog. Currently, our actual cost to fulfill the redemption of a point is approximately $.00080.

Journal Entries

We account for our loyalty program with separate and distinct transactions. First, when a member earns points, we record an estimate of the cost of the points earned. Second, when the member redeems the points, we reverse the initial estimate of the cost of the points earned and record the actual cost of the points redeemed. The following series of example journal entries reflects an initial transaction where a loyalty member earns points and two alternative subsequent transactions where the loyalty member redeems their points for a coupon or merchandise.

Initial Transaction – Member Earns Points

A member purchases $1,000 of new software with a cost of $800. The member earns 10,000 points. We estimate the cost of the 10,000 points earned at $8 (10,000 points x $.00080 per point) and record the following journal entries:

(1) Cash

$

1,000

Sales

(2) Cost of Sales

800

Inventory

(3) SG&A—Loyalty Points Earned

Accrued Liabilities—Loyalty

Subsequent Transaction – Member Redeems Points

For a Coupon—The member redeems their 10,000 points for a $10 off coupon and uses it towards the purchase of new software with a retail price of $60 and a cost of $48. We reverse the initial estimate of the cost of the points earned ($8) and record the actual cost of the points redeemed ($8). We record the following journal entries:

(4) Accrued Liabilities—Loyalty

SG&A—Loyalty Points Earned

(5) Cash

Cost of Sales

SG&A—Loyalty Rewards Redeemed

We record these journal entries to (1) recognize the sale of merchandise net of the loyalty discount,

(2) reverse the initial estimate of the cost of the points redeemed from SG&A (entry #4 above), (3) recognize the actual cost of the points redeemed in SG&A, and (4) record cost of sales to reflect gross margin at the actual gross margin of the product without the loyalty discount (20% in this example).

For Merchandise—The member redeems their

10,000 points for a gaming themed hat. The cost of the hat is $6. We reverse the initial estimate of the cost of the points earned ($8) and record the actual cost of the points redeemed ($6). We record the following journal entries:

(6) Accrued Liabilities—Loyalty

(7) SG&A—Loyalty Rewards Redeemed

Loyalty Rewards Inventory (Prepaid)

As the journal entries above indicate, we believe that the cost of our loyalty program is more appropriately reflected in selling, general and administrative expenses rather than cost of sales due to the nature of the program. Our loyalty program, which was introduced in May 2010 as a replacement for other advertising programs, is an integral part of our advertising and promotional efforts. We use this program to communicate new releases and promotions, provide member-only benefits and drive traffic into our stores, consistent with our other brand and promotional advertising programs.

Read in the reply ↗

We note your response to comment 6 from our letter dated August 16, 2013 . Although your “Other” product category account ed for only 13-17% of your revenues for the fiscal years presented, we note that it represented approximately 34 -40% of your overall gross profit.

Rest of the question

Please quantify for us the impact on revenues and gross profit for each “Other” sub-product disclosed on page 37 and referenced in our prior comment . To the extent any sub-product materially contributes to your gross profit , please provide additional disclosures in your filing to enable investors to see the company through the eyes of management or tell us why you believe such information would not be useful to investors.

We note the Staff’s request to quantify the impact on revenues and gross profit for each of our “Other” product categories and to provide additional disclosures to enable investors to see the Company through the eyes of management. In recent years, our business has evolved beyond our core businesses of selling new and pre-owned video game hardware, software and accessories to selling mobile and digital products.

The following table quantifies the impact on total revenues for each of our “Other” sub-products for the 53 weeks ended February 2, 2013 (in millions).

53 Weeks

Ended

February

Rest of the answer

2,

2013

Net

Percent of Total

Net Other Sales:

Video game accessories

635.5

7.1

%

PC entertainment software

228.3

2.6

Mobile

186.1

2.1

Digital

142.5

1.6

Game Informer and PowerUp Rewards

124.9

1.4

Other

223.1

2.5

Total

1,540.4

17.3

The following table quantifies the impact on total gross profit for each of our “Other”

Gross

Profit

Percent of

Other Gross Profit:

242.1

9.1

87.3

3.3

77.2

3.0

60.7

2.3

36.7

89.4

593.4

22.4

In future filings, we will provide our financial statement users with more visibility into our

“Other” product categories. Specifically, beginning with our Form 10-Q for the period ending November 2, 2013, we will expand our table disclosures in our Significant Products note in our notes to our consolidated financial statements to include video game accessories, digital and mobile as additional product categories. Similarly, we will expand our table disclosures in Management’s Discussion and Analysis to include video game accessories, digital and mobile as additional product categories and will discuss material changes to net sales and gross profit between periods presented for these additional product categories. We intend to include video game accessories as a separate product category in the future because it represents the largest sub-category of Other Sales. We plan to separately disclose the digital and mobile categories because these sub-categories represent significant growth opportunities for us in the near future. We intend to leave the Game

Informer, PowerUp Rewards and PC entertainment and products in the other sub-category, including toys, consumer electronics and strategy guides, as part of our Other Sales category because we do not expect that these sub-categories will become significant to us in the near future. For example, subject to change based on facts and circumstances, the table disclosures would include the following:

The following table sets forth net sales (in millions) and percentage of total net sales by significant product category for the periods indicated:

13 Weeks Ended

39 Weeks Ended

November 2, 2013

October 27, 2012

Net Sales:

New video game hardware xxx.x xx.x

New video game software

Pre-owned video game products

Digital (1)

Mobile (2)

Other (3)

The following table sets forth gross profit (in millions) and gross profit percentages by significant product category for the periods indicated:

Gross Profit:

(1)

Primarily includes video game products and content distributed digitally and digital currency.

(2)

Primarily includes new and pre-owned tablets, mobile accessories, smartphones and other mobile products and services.

(3)

Primarily includes PC entertainment and other software and revenues associated with Game Informer magazine and our PowerUp Rewards program.

We acknowledge that:

• we are responsible for the adequacy and accuracy of the disclosure in the filing;

Staff comments or changes in disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and we 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.

Read in the reply ↗

We note your response to comment 1 from our letter dated October 2, 2013 and are still unclear why you classify the costs of your loyalty program as selling, general and administrative expenses. Considering the cost of inventory is typically relieved through costs of sales, tell us why it is appropriate to classify the cost of free or discounted products earned by your customers outside of cost of sales.

The Company notes the

Staff’s view that the cost of free or discounted products under our loyalty program would be more appropriately classified as cost of sales. Upon further consideration of this view point, we have determined that in our Form 10-K for the fiscal year ending February 1, 2014, we will reclassify the fiscal 2013 year-to-date cost of free or discounted products under our loyalty program from selling, general and administrative costs to cost of sales and prospectively account for these costs as cost of sales.

We believe prospective treatment of this reclassification is

Rest of the answer

appropriate based on the quantitative and qualitative immateriality of these costs on our cost of goods sold, gross profit and selling, general and administrative expenses. Our cost of free or discounted products under our loyalty program for the 53 weeks ended February 2, 2013 and the

52 weeks ended January 28, 2012 were $15.6 million and $18.9 million, respectively. We anticipate that for the fiscal year ended February 1, 2014, our cost of free or discounted products under our loyalty program will be consistent with the amount of costs incurred in fiscal 2012 and 2011 and will represent approximately 0.3%, 0.7% and 1.0% of cost of goods sold, gross profit and selling, general and administrative expenses, respectively. Additionally, we estimate that the fiscal year ending February 1, 2014 cumulative reclassification of these costs would represent approximately 0.4%, 1.2% and 2.1% of our fourth quarter cost of goods sold, gross profit and selling, general and administrative expenses, respectively.

We intend to continue to account for the costs to administer the loyalty program, including program administration fees, program communications and cost of loyalty cards, as selling, general and administrative expenses.

We acknowledge that:

• we are responsible for the adequacy and accuracy of the disclosure in the filing;

Staff comments or changes in disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and we 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.

Read in the reply ↗