United States securities and exchange commission logo August 20, 2020 Corey Sanders Chief Financial Officer MGM Resorts International 3600 Las Vegas Boulevard South Las Vegas, NV 89109 Re: MGM Resorts International Form 10-K for the year ended December 31, 2019 Filed February 27, 2020 File No. 001-10362 Dear Mr. Sanders: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Real Estate & Construction