December 4, 2019

Andrew Hagopian, III, Esq.
Secretary
MGM Growth Properties Operating Partnership LP
6285 S. Rainbow Blvd., Suite 500
Las Vegas, Nevada 89118

       Re: MGM Growth Properties Operating Partnership LP
           Registration Statement on Form S-4
           Filed November 25, 2019
           File No. 333-235232

Dear Mr. Hagopian:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

       Please contact Ronald (Ron) Alper at (202) 551-3329 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Real
Estate & Construction
cc:    Rod Miller