January 30, 2020
Giovanna Cipriano
Senior Vice President and Chief Accounting Officer
Foot Locker, Inc.
330 West 34th Street
New York, NY 10001
Re: Foot Locker, Inc.
Form 10-Q for the Period Ended November 2, 2019
Filed December 11, 2019
File No. 001-10299
Dear Ms. Cipriano:
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 the comment 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 our
comment apply to your facts and circumstances, please tell us why in your
response.
After reviewing your response to the comment, we may have additional
comments.
Form 10-Q for the Period Ended November 2, 2019
Notes to the Condensed Consolidated Financial Statements
3. Segment Information, page 8
1. You disclose you have three operating segments (North America, EMEA and
Asia
Pacific). You further indicate you have aggregated these operating
segments into one
reportable segment based upon their shared customer base and similar
economic
characteristics. Please explain to us in detail how the customer base is
shared and how
this meets the applicable criteria for aggregation contained in ASC
280-10-50-11.
Likewise, demonstrate how the economic characteristics are similar among
the three
separate geographic operating segments and how you determined the
segments can be
expected to essentially have the same future prospects. In your response,
tell us the
measure(s) you consider to be economically similar and why such
measure(s) was
selected.
Giovanna Cipriano
Foot Locker, Inc.
January 30, 2020
Page 2
In closing, 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.
You may contact Stephen Kim at 202-551-3291 or Doug Jones at
202-551-3309 with any
questions.
FirstName LastNameGiovanna Cipriano Sincerely,
Comapany NameFoot Locker, Inc.
Division of
Corporation Finance
January 30, 2020 Page 2 Office of Trade &
Services
FirstName LastName