Mail Stop 3561
December 9, 2005
David G. Barnes
Chief Financial Officer
RadioShack Corporation
300 RadioShack Circle
Ft. Worth, TX 76102
Re: RadioShack Corporation
Form 10-K for the Fiscal Year Ended December 31, 2004
Forms 10-Q for Fiscal Quarter Ended September 30, 2005
File No. 1-5571
Dear Mr. Barnes:
We have reviewed your filings and have the following
comments. Where indicated, we think you should revise your
documents
in response to these comments. If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary. Please be as detailed as necessary in your
explanation. In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.
Please understand that the purpose of our review
process is to assist you in your compliance with the applicable
disclosure requirements and to enhance the overall disclosure in
your
filings. We look forward to working with you in these respects.
We
welcome any questions you may have about our comments or on any
other
aspect of our review. Feel free to call us at the telephone
numbers
listed at the end of this letter.
Form 10-K for the period ended December 31, 2004
Notes to the Financial Statements
Note 2 - Summary of Significant Accounting Policies
1. We have read your revenue recognition policy with respect to
commissions and residual payments received from wireless and
satellite system operators. Tell us in more detail what guidance
you
have relied upon in support of your revenue recognition policy as
it
applies to these forms of revenue. Tell us whether you considered
of
EITF 00-21. Tell us in more detail how customer deactivations
affect
the amount of commission received at the time a new customer is
activated. Provide us with an explanation of the differences
between
the up-front commission and the residual commission and what
services
you provide to earn each of those revenues. Tell us how much you
recorded in revenue related to the commissions received upon
obtaining a new customer and residual revenue for each period
presented.
Note 9 - Accrued Expenses and other Current Liabilities
2. We note that you have recorded deferred gift card revenues.
Tell
us now, and in future filings disclose, your policies with regard
to
gift card breakage.
Note 24 - Product Sales Information
3. It appears based upon your disclosures that revenues from the
sales of services may exceed 10% of total revenues. Tell us what
was
your consideration of Regulation S-X Rule 5-03 with regard to the
presentation of a separate line for revenues and cost of sales
associated with services. In your response please address in
detail
which sales you associate with tangible products and sales that
you
associate with services.
4. Tell us in more detail your consideration of reportable
segments.
We note that you have manufacturing operations, a wholesale
channel,
online sales, retail support operations provided to third parties,
and service centers. While we presume that each of these revenues
sources would provide less than 10% of total revenues, we note
that
in the absence of meeting certain aggregation criteria, it would
be
inappropriate to aggregate these operations with your primary
retail
operations if discreet financial information is produced for these
businesses and this information is used by management to operate
your
company.
* * *
As appropriate, please amend your filings and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information. Detailed cover letters
greatly
facilitate our review. Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company 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.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact me at (202) 551-3841 if you have questions
regarding the comments.
Sincerely,
Michael Moran
Branch Chief
??
??
??
??
David G. Barnes
RadioShack Corporation
December 9, 2005
Page 1