MTR GAMING GROUP, INC.
State Route 2 South
P.O. Box 356
Chester, WV 26034
February 5, 2010
Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 3561
100 F Street, N.W.
Washington, D.C. 20004
ATTN: Ms. Lauren Nguyen, Esq.
MTR Gaming Group, Inc. (the “Registrant)
Amendment No. 2 to Registration Statement on Form S-4
(Registration No. 333-163018)
Dear Ms. Nguyen:
Pursuant to Rule 461 of the Securities Act of 1933, as amended, the Registrant hereby requests acceleration of the effective date of its Registration Statement to February 8, 2010, at 4:00 p.m., or as soon as practicable thereafter.
The Registrant acknowledges that (1) should the Commission or 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; (2) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (3) the Registrant may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
| Sincerely, |
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| /s/ David R. Hughes |
| David R. Hughes |
| Corporate Executive Vice President and Chief Financial Officer |
