April 26, 2005


Mail Stop 04-09

Mr. Gary L. Carano, CEO
407 North Virginia Street
Reno, Nevada 89501

Re:	Circus and Eldorado Joint Venture Silver Legacy Capital Corp.
	Form 10-K for the year ended December 31, 2004
	File No. 333-87202

Dear Mr. Carano:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  As such, all persons who are responsible for the
adequacy
and accuracy of the disclosure are urged to be certain that they
have
included all information required pursuant to the Securities
Exchange
Act of 1934.

      Where indicated, we think you should revise your documents
in
response to these comments in future filings.  If you disagree, we
will consider your explanation as to why our comment is
inapplicable
or a revision is unnecessary.  Please be as detailed as necessary
in
your explanation.  In some of our comments, we may ask you to
provide
us with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-KSB

Financial Statements and Notes

Note 1 - Summary of Significant Accounting Policies and Basis of
Presentation

Casino Revenues and Promotional Allowances, page F-8
1. In future filings, revise your revenue recognition policy to
include how your estimate of the amount of chips to be redeemed by
customers effects revenue recognition.

Changes in Estimates, page F-9
2. We note that at December 31, 2003, the Partnership increased
casino revenues by $964,000 for outstanding chips and tokens not
expected to be redeemed by customers.  Clarify to us the basis for
increasing revenue for this adjustment and how you determined that
the entire amount related to 2003.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your proposed revisions for
future
filings that keys your responses to our comments and provides any
requested supplemental information.  Detailed cover letters
greatly
facilitate our review.  Please file your cover letter on EDGAR.
Please understand that we may have additional comments after
reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.










      You may contact Yolanda Crittendon, Staff Accountant, at
(202)
942-1868 or the undersigned at (202) 942-1964 if you have
questions.



						Sincerely,



Linda Van Doorn
Senior Assistant Chief Accountant

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Circus and Eldorado Joint Venture Silver Legacy Capital Corp.
April 26, 2005
Page 1