SecProbe.io

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Mail stop 03-05

      April 13, 2005

Via Fax & U.S. Mail

Mr. Daniel R. Lee
Chairman and Chief Executive Officer
Pinnacle Entertainment, Inc.
3800 Howard Hughes Parkway
Las Vegas, NV 89109

Re:	Pinnacle Entertainment, Inc. (the "Company")
      Form 10-K for the year ended December 31, 2004
      File No. 1-13641
	Filed March 16, 2005

Dear Mr. Lee:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

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

Consolidated Statements of Operations, page 50
1. It is not apparent from Management`s Discussion and Analysis of
Financial Condition and Results of Operations on page 19 what type
of
revenue is included in "Other operating income" in the statements
of
operations.  Please tell us what type of revenue is included and
revise future discussions to disclose the nature of amounts
included
in this section of the statement of operations.

Note 8 - Lease Obligations, page 72

2. It is not apparent from your disclosure how you are accounting
for
the lease agreement related to the 227 acres for the L`Auberge du
Lac
Hotel and Casino.  It appears you have taken possession of the
land
related to this property in order to perform construction
activities.
Under guidance in paragraph 2 of FASB Technical Bulletin 88-1 (FTB
88-1), the rental period should include the period of time when
the
lessee takes possession or controls the physical use of the
property
and lease payments should be expensed straight line over the
entire
term, including the construction period.  Please explain how you
have
considered guidance in FTB 88-1 in relation to your lease
agreements
for L`Auberge du Lac, St. Louis County and any other properties
that
would involve a similar arrangement.  For additional guidance,
refer
to FTB 85-3 and FAS 13.

Schedule II - Valuation and Qualifying Accounts, page 89
3. Please explain the nature of amounts included as asset sale
reserves.

Other
4. We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* 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; and

* the company 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.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

* * * * *

      Please file your response to our comments via EDGAR within
15
business days from the date of this letter.  Please understand
that
we may have additional comments after reviewing your response.
You
may contact Tracie Northan at 202-824-5479 or James Campbell at
202-
942-1914 if you have questions regarding comments on the financial
statements and related matters.

Sincerely,

Michael Fay
Branch Chief Accountant

Via facsimile:  Stephen H. Capp, CFO
		(702) 784-7778

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