Greektown Superholdings, Inc.
555 East Lafayette
Detroit, Michigan 48226
December 27, 2010
VIA EDGAR SUBMISSION
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Mail Stop 3561
Attention: John Dana Brown, Justin Dobbie
| Re: | Greektown Superholdings, Inc. |
| | Registration Statement on Form S-4 |
| | File No. 333-169476 |
Ladies and Gentlemen:
Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, the undersigned Registrants hereby request that the effectiveness of the above-captioned Registration Statement be accelerated so that it will become effective as of 9:00 a.m. on December 29, 2010, or as soon thereafter as practicable.
The Registrants acknowledge that:
1. should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;
2. the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
3. the Registrants may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours, |
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GREEKTOWN SUPERHOLDINGS, INC. |
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BY: | /s/ Clifford J. Vallier |
| Name: Clifford J. Vallier |
| Title: President, Chief Financial Officer and |
| Treasurer |
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| GREEKTOWN NEWCO SUB, INC. |
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BY: | /s/ Clifford J. Vallier |
| Name: Clifford J. Vallier |
| Title: President, Chief Financial Officer and |
| Treasurer |
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| GREEKTOWN HOLDINGS, L.L.C. |
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BY: | /s/ Clifford J. Vallier |
| Name: Clifford J. Vallier |
| Title: Chief Executive Officer |
GREEKTOWN CASINO, L.L.C. |
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BY: | /s/ Clifford J. Vallier |
| Name: Clifford J. Vallier |
| Title: Chief Executive Officer |
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CONTRACT BUILDERS CORPORATION |
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BY: | /s/ Clifford J. Vallier |
| Name: Clifford J. Vallier |
| Title: Chief Executive Officer |
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REALTY EQUITY COMPANY |
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BY: | /s/ Clifford J. Vallier |
| Name: Clifford J. Vallier |
| Title: Chief Executive Officer |