November 16, 2005 Mail Stop 4561 Via U.S. Mail and Fax (609) 441-4624 Ms. Denise Barton Chief Financial Officer Atlantic Coast Entertainment Holdings, Inc. c/o Sands Hotel & Casino Indiana Avenue & Brighton Park Atlantic City, NJ 08401 RE:	Atlantic Coast Entertainment Holdings, Inc. Form 10-K for the fiscal year ended December 31, 2004 Filed April 15, 2005 Form 10-K/A for the fiscal year ended December 31, 2004 Filed September 15, 2005 Forms 10-Q and 10-Q/A for the quarterly periods ended March 31, 2005 and June 30, 2005 File No. 333-110484 Dear Ms. Barton: We have reviewed your response letter dated November 2, 2005 and have the following additional comment. In our comments, we ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may 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 comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Note 2 - Summary of Significant Accounting Policies Casino Revenues, Promotional Allowances and Departmental Expenses, page 36 1. Your response to prior comment 1 indicates that the amounts in the table on page 36 are associated with the costs deducted from gross revenues on the Statement of Operations with no other amounts included therein. Please explain to us why the amounts shown on the table differ from the amounts on the Statement of Operations. Please respond to the comments included in this letter within ten business days. If you have any questions, you may contact William Demarest at (202) 551-3432 or me at (202) 551-3486. Sincerely, Daniel L. Gordon Branch Chief ?? ?? ?? ?? Atlantic Coast Entertainment Holdings, Inc. November 16, 2005 Page 1