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January
26, 2007
VIA
EDGAR
United
States Securities and Exchange Commission
Division
of Corporation Finance
Mail
Room
4561
100
F
Street, N.E.
Washington,
D.C. 20549
Attention:
Megan Akst
| Re: |
Item
4.02 Form 8-K
|
|
Filed
on December 11, 2006
File
No.
0-29230
|
Ladies
and Gentlemen:
Take-Two
Interactive Software, Inc. (the “Company”) is in receipt of the Staff’s comment
letter dated December 12, 2006 regarding its current report on Form 8-K filed
on
December 11, 2006. As part of the Company’s desire to be responsive to the
Staff’s comments, our counsel informed Ms. Akst of the Company’s Form 8-K
updating the current status of the stock option review by the Special Committee
of the Company’s Board of Directors prior to the filing of the Form 8-K on
January 22, 2007. As our counsel explained to Ms. Akst, because the report
of
the Special Committee’s advisors was first submitted to the Company late last
week, the Company is still determining the impact the findings will have on
the
Company’s financial statements, including the financial impact related to the
disqualification of any incentive stock options and related disclosures.
Pursuant to your request, the Company hereby informs you that it currently
intends to respond to the comment letter as soon as practicable. The Company
will continue to apprise the Staff as to its progress. The Company thanks the
Staff for continuing to work with it on this matter.
|
Very
truly yours,
/s/
Karl H. Winters
Karl
H. Winters
Chief
Financial Officer
Take-Two
Interactive Software, Inc.
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