August 12, 2019



Via Email

W. Garrett Crotty
International Speedway Corporation
One Daytona Boulevard
Daytona Beach, FL 32114

       Re:     International Speedway Corp.
               PRER14A filed August 9, 2019
               File No. 0-02384

               Schedule 13E-3/A filed August 9, 2019
               Filed by NASCAR Holdings, Inc. et al.
               File No. 5-36579

Dear Crotty:

        The staff in the Office of Mergers and Acquisitions has reviewed the
amended filings
listed above. We have the following additional comments. All defined terms used
here have the
same meaning as in your revised preliminary proxy statement.

PRER14A filed August 9, 2019

Litigation, pages 11 and 63

   1. Refer to comment 1 in our prior comment letter dated July 18, 2019. We
note the new
      disclosure that no agreement in principal has been reached with respect
to fees and
      expenses for Plaintiff's Counsel. However, to the extent that a range of
fees and
      expenses were discussed by the parties, please disclose. We believe that
since Plaintiff's
      Counsel was extensively involved in negotiating the terms of this
transaction, its interest
      in the same should be described to the fullest extent possible.

Special Factors   Background of the Merger, page 18

   2. Refer to comment 7 in our prior comment letter and your response. We are
unable to
      locate the summary of the matters outlined in comment 7(a)-(c). Please
revise or advise.
 W. Garrett Crotty
International Speedway Corp.
August 12, 2019
Page 2

Summary of Presentations Provided by Goldman Sachs, page 39

      3. We reissue comment 11 in our prior comment letter. We are unable to
locate responsive
         disclosure in this section explaining what specific procedures Goldman
failed to follow
         here that would have ordinarily been followed, had it issued a
fairness opinion. The
         reference to "certain other procedures" on page 39 is not helpful.

      4. The revised language on page 40 of the revised proxy statement
references non-public
         information reviewed and considered by Goldman in conducting its
analysis. It is not
         clear that this non-public information is included in the forecasts
and projections
         summarized later in the proxy statement. Please revise to include, or
advise.

      5. To the extent additional projections disclosure is included in
response to our last
         comment above, we direct your attention to comment 14 in our July 18,
2019 letter.

      6. In the third from the last paragraph on page 41, you state that the
foregoing is a
         "summary of certain of the material financial analyses contained in
the Goldman Sachs
         Presentations." Please revise to confirm that all material financial
analyses are described.

The Goldman Sachs Presentations, page 41

      7. Revise this section generally to provide the results yielded by each
of the analyses
         conducted by Goldman.

Preliminary Valuation Analysis provided by Plaintiff's Counsel, page 64

      8. Clarify whether Plaintiff's Valuation Materials (dated February 12,
2019) were
         assembled by Plaintiff's Counsel, by Global Economics Group, or some
other third party.

       We remind you that the Company and other filing persons on the Schedule
13E-3 are
responsible for the accuracy and adequacy of their disclosures in both filings,
notwithstanding
any review, comments, action or absence of action by the staff.

         Please contact me at 202-551-3263 with any questions.

                                                               Sincerely,

                                                               /s/ Christina
Chalk

                                                               Christina Chalk
                                                               Senior Special
Counsel
                                                               Office of
Mergers & Acquisitions

cc:      Michael Gold, Esq. (via email)
         Beverly Reyes, Esq. (via email)