MIDWAY GAMES INC. 2704 West Roscoe Street Chicago, Illinois 60618 773.961.2850 fax 773.961.2299 December 2, 2004 VIA EDGAR Securities and Exchange Commission 450 Fifth Street, NW Washington, D.C. 20549 Re: MIDWAY GAMES INC. Registration Statement on Form S-3 Ladies and Gentlemen: On behalf of Midway Games Inc., I am transmitting for filing under the Securities Act of 1933, as amended, a Registration Statement on Form S-3, including exhibits. The fee for the filing has been offset pursuant to Rule 457(p) as noted in the footnotes to the fee calculation table. Please direct any questions regarding the filing to the undersigned. Very truly yours, /s/ Deborah K. Fulton -------------------------- Deborah K. Fulton, Senior Vice President, Secretary and General Counsel