SecProbe.io

Mail Stop 3561
        October 25, 2006

Via Fax & U.S. Mail

Mr. Todd Huss
Chief Financial Officer
5455 Spine Road, Suite C
Boulder, Colorado 80301

Re: Global Casinos, Inc.
 Form 10-KSB for the year ended June 30, 2006
Filed October 10, 2006
 File No. 000-15415

Dear Mr. Huss:

We have reviewed your filing and have the following comments.  Unless
otherwise indicated, we think you should revi se your document in future filings in
response to these comments.  If you disagree, we will consider your explanation as to
why our comment is inapplicable or a revisi on is unnecessary.  Please be as detailed as
necessary in your explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  Af ter reviewing this
information, we may raise additional comments.

 Please understand that the purpose of our re view 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.

Please respond to confirm that such comments will be complied with, or, if
certain of the comments are deemed inappropr iate, advise the staff of your reason.  Your
response should be submitted in electronic form, under the label “corresp” with a copy to the staff.  Please respond w ithin ten (10) business days.

Form 10-KSB for the year ended June 30, 2006

Management’s Discussion & Analysis

- General

Mr. Todd Huss
Global Casinos, Inc.
October 25, 2006 Page 2

1. In future filings, please expand your MD&A section to include a discussion of
your critical accounting estimates and polic ies.  The discussion should address the
following areas:
• Types of assumptions underlying th e most significant and subjective
estimates;
• Sensitivity of those estimates to d eviations of actual results from
management’s assumptions; and
• Circumstances that have resulted in  revised assumptions in the past.
Refer to SEC Release No. 33-8350 for guidan ce.  In addition, consider including a
discussion of your impairment of long-lived  assets, income taxes, and stock based
compensation, within your critical accounting policies and estimates section.

– Liquidity

2. Please revise future filings to disclose the estimated amount of capital expenditures for the year ended June 30, 2007.

– Other

3. We note that although holders of appr oximately $200,000 did not agree to accept
a reduced interest rate and extended maturity date, you have been making payments based on the modifications and have  taken the position that their lack of
objection represents a legally enforceab le modification.  Please tell us the
difference in the amount of interest that will be paid under the modified rate
versus the original rate and how you have determined or calculated the amount of
interest accrued.  Also, please explain to us in further detail why you believe you will not be obligated to pay the amount of  interest required by the original terms
of the agreement.

Consolidated Financial Statements

Balance Sheet

4. We note your presentation of an asset titl ed “accrued gaming income” on the face
of the balance sheet.  Pl ease explain to us, and disclose in the notes to the
financial statements in future filings, the nature of this asset.

Mr. Todd Huss
Global Casinos, Inc.
October 25, 2006 Page 3

Notes to the Financial Statements

– General

5. We note from your disclosure on page 6 that you have a fre quent player club
called the “Sharpshooter Club.”  Please te ll us and explain in the notes to your
financial statements in future filings, the na ture of the rewards, if any, that may be
redeemed by the customers, (i.e., cash, food and other goods and services). Also
please explain how you recognize and clas sify awards earned by customers under
this program and tell us how you have  applied the guidance of EITF 00-22.

6. Please revise future filings to disclose a ny securities that could potentially dilute
EPS in the future, but which were not included in the calculation of diluted EPS because to do so would have been antidilutive for the periods presented.  See paragraph 40(c) of SFAS No. 128.

7. In your consolidated financial statements  we note no disclosu re of the accounting
method for accruing a base jackpot liability.  With respect to the method for accruing this liability, casino companies have interpreted the requirement in
Section 2.09-.10 of the Casino Audit guide di fferently.   In this  regard, we have
noted that some accrue the liability as games are played under a matching
concept, while others accrue only increm ental jackpot amounts owed where every
coin played adds to the j ackpot total.   Pl ease expand your notes to describe this
liability and address how  you recognize and measure the liability in your
consolidated financial statements.

Note 2. Gain From Debt Restructuring

8. We note your disclosure that during fi scal 2005 you converted certain notes
payable into equity by issuing 110,000 shares of common stock in exchange for principal of $110,000 and accrued interest of $103,000.  Please tell us how you determined the market value of the st ock issued and your  basis for issuing
common stock with a market  value of only $104,500 which resulted in a gain on
the extinguishment of debt.  Also, please tell us how you were  able to retire
certain mortgage debts at a discount a nd how you accounted for the transaction.
Please ensure your response addresses your consideration of APB 26 and FTB 80-
1, as applicable.  Additionally, for each of the debt extinguishment or conversion
transactions in which a gain  was recognized, please tell us if the transaction was
with a related party.   We may have further comment upon review of your response.

Mr. Todd Huss
Global Casinos, Inc.
October 25, 2006 Page 4

Note 7. Stock Incentive Plan

9. We note that you disclose the assumptions used in the Black-Scholes option
pricing model for the stock grants during the year ended June 30, 2006.  In future filings, please include a description of the signifi cant assumptions used to
estimate the fair value of grants made in  each year for which an income statement
is presented.  See paragraph 47(d) of  SFAS No. 123 and paragraph A240(e) of
SFAS No. 123(R).

Note 9. Investment in Global Gaming Technologies

10. Please tell us and revise No te 9 to explain how you plan  to account for your 25%
interest in Global Gaming Technologies. Also, please explain why you believe it
is appropriate to reflect an investment and an obligation for the $90,000 of your unpaid capital contribu tion at June 30, 2006.

Summary Compensation Table, page 52

11. We note the disclosure in footnote (1) indicating that Mr. Neuman receives no compensation for his services as Interim president. Please revise to reflect the fair
value of the services provided by Mr. Ne uman as compensation expense and as a
capital contribution in the Company’s fina ncial statements or explain why you do
not believe this is required. Refer to  the guidance outlined in Topic Seven,
Section II.B of the Division of Corpor ation Finance’s Staff Training Manual.

********

  We urge all persons who are responsi ble for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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

Mr. Todd Huss
Global Casinos, Inc.
October 25, 2006 Page 5

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 advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

 You may contact Claire Erlanger at  (202) 551-3301 if you have questions
regarding comments on the financia l statements and related matte rs.  Please contact me at
(202) 551-3813 with any other questions.

Sincerely,

Linda Cvrkel
Branch Chief