Marina District Finance Company, Inc.
Marina District Development Company, LLC
One Borgata Way
Atlantic City, New Jersey 08401
May 25, 2011
Via EDGAR Transmission
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E., Mail Stop 4631
Washington, D.C. 20549
| Attention: | Michael McTiernan |
| Re: | Marina District Finance Company, Inc. |
| Marina District Development Company, LLC |
| Registration Statement on Form S-4 (Nos. 333-173275 and 333-173275-01) |
Dear Mr. McTiernan:
Pursuant to Rule 461 of the Securities Act of 1933, as amended, we hereby request acceleration of the effective time of the above-referenced Registration Statement of Marina District Finance Company, Inc. and Marina District Development Company, LLC (collectively, the “Company”), so that it may become effective at 4:00 P.M., Washington, D.C. time, as of May 26, 2011, or as soon as possible thereafter.
Furthermore, we hereby acknowledge that:
| • | should the U.S. Securities and Exchange Commission (the “Commission”) or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| • | the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Company 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. |
Sincerely,
Marina District Finance Company, Inc.
Marina District Development Company, LLC
| By: | /s/ Josh Hirsberg | |||
| Josh Hirsberg | ||||
| Vice President, Chief Financial Officer and Treasurer (Marina District Finance Company, Inc.) | ||||
| Principal Financial Officer | ||||
| and Principal Accounting Officer (Marina District Development Company, LLC) |
