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      Unassociated Document

    June
      15,
      2005

    United
      States Securities & Exchange Commission

    Ms.
      Claire Lamoureux

    Division
      of Corporate Finance

    Washington,
      D.C. 20549

    Subject:
      Florida Gaming Corporation

    Form
      10-KSB for the year ended December 31, 2004

    Form
      10-QSB for the period ended March 31, 2005

      Commission File #: 000-09099

    Dear
      Ms.
      Lamoureux:

    The
      following is in response to the subject letter to Florida Gaming Corporation
      (the “Company”), dated July 1, 2005.

          1.

            Future
              filings will include a section detailing the critical accounting estimates
              in the MD&A.
              We will refer to Financial Reporting Policy 60 and Release No. 33-8350
              for
              guidance.

          2.

            Future
              filings will describe the reason for material changes from period to
              period. We will also provide an analysis and quantification in line
              items.
              We will refer to Item 303 (b)(1)(vi) of Regulation
              S-B.

          3.

            Future
              filings will discuss the net working deficit and we will refer to Item
              303(b) (1) of Regulation S-B.

          4.

            We
              understand that APB 30 requires us to consider the environment in which
              we
              operate and that Florida routinely faces hurricanes and tropical storms.
              However, in this case, history was made when two category 3 hurricanes
              made land fall at Ft. Pierce, Florida within three weeks. The extent
              of
              the damage and thus the insurance claim and gain were increased
              dramatically by the second hurricane because the first hurricane removed
              the roof from the Ft. Pierce fronton building. While we do not believe
              a
              single hurricane in a year would be unusual in nature, certainly, two
              hurricanes in three weeks in exactly the same place is highly unusual.
              Of
              course, nothing like this has happened for over 40 years in Florida
              so it
              is certainly infrequent. We believe a fair analog would be tornadoes
              in
              the Midwest. Certainly, it isn’t unusual for tornadoes to form and touch
              down in the Midwest but it would be highly unusual for two tornadoes
              to
              form and touch down in the same city in a three-week period. We believe
              the treatment we have afforded the gain provides the best measure of
              our
              economic performance to our shareholders. We do not believe
              it is appropriate to include the gain in our income from continuing
              operations but, upon your direction in your letter, we will revise
              future
              filings to reclassify the gain from extraordinary to a separately stated
              item of income from continuing
              operations.

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            5.

              We
                understand and concur with your advice on the presentation of preferred
                dividends in our statements of
                operations.

          6.

            We
              will revise future filings to disclose the useful lives of each class
              of
              our property and equipment.

          7.

            In
              2004 we recognized a loss on real estate activities that included a
              provision to increase a valuation reserve we maintain on houses and
              lots
              we are holding out for sale. The impairment loss was not related to
              a
              long-lived asset. The valuation for the houses and lots was based on
              appraisals determined by comparable sales in the same development.
              We will
              include an expanded description of the above information in future
              filings.

          8.

            Jai-alai
              and intertrack mutual commissions are recognized immediately upon the
              completion of the event upon which the related wagers are placed. In
              general, wagers are placed immediately prior to the event upon which
              the
              wager is placed. The wagers are generally made in cash or other good
              funds
              and subject to state escrow requirements so collectibility is never
              an
              issue. SAB 101, Topic 13, deals with revenue recognition. We believe
              the
              timing of the revenue recognition is appropriate because we recognize
              the
              revenue after it is earned. Further, the collection of the funds is
              not in
              question. Finally, with respect to the inclusion of disclosures regarding
              our handle on the face of the Statement of Operations, we believe the
              handle data is important to the understanding of the trends in parimutuel
              commission income. We would be happy to move this information to our
              footnote disclosures if you believe that would be preferable
              presentation.

          9.

            Our
              policy is to capitalize any advertising costs that benefit future periods
              through name branding. We have incurred no such expenses in the last
              two
              years. All of our advertising costs have been expensed as incurred
              because
              they relate to promotions for particular events and seasonal activities
              that do not benefit future periods. There were no capitalized advertising
              costs at December 31, 2004 or 2003.

          10.

            We
              will begin using tabular presentation of stock options in future
              filings.

          11.

            The
              fair market value of the stock optioned on both dates in question was
              below the strike price of both options. The market values were $2.85
              per
              share on June 13, 2003 and $3.50 per share on September 23,
              2003.

          12.

            The
              real estate valuation reserve is the same reserve discussed in Item
              7
              above. The purpose of the reserve is to lower the carrying value of
              our
              retail real estate inventory to realizable (fair market)
              value.

          13.

            We
              will revise future filings to reflect paragraph 47 of FAS
              109.

          14.

            The
              presentation of our loss from real estate activities as a one line
              item is
              driven by the fact that we had no sales in 2004. Accordingly, the line
              contains only expenses. Because our primary business has been and is
              expected to be the gaming business, we have treated our retail real
              estate
              sales activity as other income and losses as opposed to operating income
              combined with our gaming operations. This presentation is consistent
              with
              all previous years. We are open to any ideas you have for improving
              our
              financial reporting in this area.

          15.

            Please
              find below, the information requested pertaining to FAS 131, paragraph
              32.

              All
                amounts in table are in thousands

              PROFIT

              ASSETS

              REVENUES

              (LOSS)

              Florida
                Gaming Centers

              80%

              15,972

              100%

              9,466

              91%

              (4,383)

              Tara
                Club Estates

              20%

              3,881

              0%

              -

              9%

              (411)

              Consolidated
                Total

              100%

              19,853

              100%

              9,466

              100%

              (4,794)

          16.

            The
              contingent liability disclosed in Note O still exists. We will continue
              to
              include information on this matter in future
              filings.

          17.

            Future
              filings of Form 10QSB will reflect the above responses to the comments
              found in your letter.

    I
      would
      like to thank you for the analysis of our financial reporting. We are striving
      to improve our reporting as we fully implement the provisions of Sarbanes-Oxley
      Act. The Company is aware that we are responsible for the adequacy and accuracy
      of the disclosure in the filings. The Company knows that staff comments or
      changes to disclosure in response to staff comments do not foreclose the
      Commission from taking any action with respect to the filing. The Company is
      also aware that we may not assert staff comments as a defense in any proceeding
      initiated by the Commission or any person under the federal securities laws
      of
      the United States.

    If
      you
      have any further questions, please do not hesitate to contact the undersigned
      at
      (502) 589-2000 or facsimile (812) 945-7717. My mailing address is Florida Gaming
      Corporation, 2669 Charlestown Road, Suite D, New Albany, IN 47150.

    Sincerely,

    Kimberly
      R. Tharp

    Chief
      Financial Officer

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