TAKE TWO INTERACTIVE SOFTWARE INC — Regulatory Filings 2019

Nov 4, 2019

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November 4, 2019

VIA EDGAR

Kathleen Collins

Accounting Branch Chief

Division of Corporation Finance

Office of Information Technologies and Services

U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549

Re: Take-Two Interactive Software, Inc. Form 10-K for the Fiscal Year Ended March 31, 2019 Filed May 14, 2019 Form 8-K furnished August 5, 2019 File No. 001-34003

Dear Ms. Collins:

On behalf of Take-Two Interactive Software, Inc. (the “ Company ”), we submit this letter in response to comments from the staff of the Securities and Exchange Commission received by letter dated October 31, 2019 (the “ Comment Letter ”) relating to the above-referenced filings. We are working expeditiously to respond to the Comment Letter. In light of the fact that we are currently focusing on our earnings and Form 10-Q filings, we respectfully request an extension of time to respond to the inquiries contained in the Comment Letter. We currently anticipate submitting a response to the Comment Letter on or before December 2, 2019. Please do not hesitate to contact me at 646-536-3003 with any concerns you may have regarding the timetable described above. Thank you for your consideration.

Very truly yours,

/s/ Lainie Goldstein

Lainie Goldstein

cc: Daniel Emerson