EXHIBIT 8.1

                          [BRYAN CAVE LLP LETTERHEAD]

August 31, 2005


GameStop Corp.
625 Westport Parkway
Grapevine, Texas 76051

Re:   Agreement and Plan of Merger Dated as of April 17, 2005 by and among
      GameStop Corp., GameStop, Inc., GSC Holdings Corp., Cowboy Subsidiary LLC,
      Eagle Subsidiary LLC and Electronics Boutique Holdings Corp.

Ladies and Gentlemen:

      We have acted as counsel to GameStop Corp., a Delaware corporation
("GameStop"), in connection with the Agreement and Plan of Merger (the "Merger
Agreement"), dated as of April 17, 2005, by and among GameStop, GameStop, Inc.,
a Minnesota corporation, GSC Holdings Corp., a Delaware corporation and wholly
owned subsidiary of GameStop, Inc. ("Holdco"), Cowboy Subsidiary LLC, a Delaware
limited liability company and wholly-owned subsidiary of Holdco, Eagle
Subsidiary LLC, a Delaware limited liability company and wholly-owned subsidiary
of Holdco, and Electronics Boutique Holdings Corp., a Delaware Corporation
("Electronics Boutique"). The time at which the Mergers become effective is
hereafter referred to as the "Effective Time." For purposes of this opinion,
capitalized terms used and not otherwise defined herein shall have the meaning
ascribed thereto in the Merger Agreement. This opinion is being delivered in
connection with the Registration Statement on Form S-4 (Registration No.
333-125161) (the "Registration Statement") filed by Holdco with the Securities
and Exchange Commission under the Securities Act of 1933, as amended.

      We have examined (i) the Merger Agreement, (ii) the Registration Statement
and (iii) the representation letters delivered to us for purposes of this
opinion by GameStop, Electronics Boutique, Holdco, and certain of their
shareholders (the "Representation Letters"). In addition, we have examined, and
relied as to matters of fact upon, originals or copies, certified or otherwise
identified to our satisfaction, of such corporate records, agreements,
documents, and other instruments and made such other inquiries as we have deemed
necessary or appropriate to enable us to render the opinion set forth below. In
such examination, we have assumed the genuineness of all signatures, the legal
capacity of natural persons, the authenticity of all documents submitted to us
as originals, the conformity to original documents of all documents submitted to
us as duplicates or certified or conformed copies, and the



August 31, 2005
Page 2



authenticity of the originals of such latter documents. We have not, however,
undertaken any independent investigation of any factual matter set forth in any
of the foregoing.

      In rendering such opinion, we have assumed, with your permission, that (i)
the Mergers will be effected in accordance with the Merger Agreement, (ii) the
information set forth in the Registration Statement and the statements
concerning the Mergers set forth in the Merger Agreement are true, complete and
correct and will remain true, complete and correct at all times up to and
including the Effective Time, (iii) the representations made by the parties in
their respective Representation Letters are true, complete and correct and will
remain true, complete and correct at all times up to and including the Effective
Time, and (iv) any representations made in the Merger Agreement or the
Representation Letters "to the knowledge of", or based on the belief of the
respective parties, or any representations similarly qualified are true,
complete and correct and will remain true, complete and correct at all times up
to and including the Effective Time, in each case without such qualification. We
have also assumed that the parties have complied with and, if applicable, will
continue to comply with, the covenants contained in the Merger Agreement.

      Based upon the foregoing, and subject to the assumptions, qualifications
and limitations stated herein and the assumptions, qualifications and
limitations set forth in the Registration Statement, the discussion set forth in
the Registration Statement under the heading "THE MERGER -- Material United
States Federal Income Tax Consequences," to the extent that such discussion
relates to matters of United States federal income tax law, is accurate in all
material respects.

      We express our opinion herein only as to those matters specifically set
forth above and no opinion should be inferred as to the tax consequences of the
Mergers under any state, local or foreign law, or with respect to other areas of
United States federal taxation. We do not express any opinion herein concerning
any law other than the federal income tax law of the United States.

      This opinion has been prepared for GameStop in connection with the
Mergers. The use of this opinion is limited to GameStop and its stockholders. It
may not be relied upon in any manner or for any purpose by any other person or
entity without our prior written consent. We hereby consent to the filing of
this opinion as an exhibit to the Registration Statement, and to the references
to our firm name therein. In giving such consent, we do not thereby admit that
we are in the category of persons whose consent is required under Section 7 of
the Securities Act of 1933, as amended, or the rules and regulations thereunder.

                                         Very truly yours,

                                         /s/ Bryan Cave LLP