SecProbe.io

Mail Stop 3561
        December 5, 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 response letter  dated November 22, 2006 and have the
following comments.  Unless otherwise indi cated, we think you should revise 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 revision is unnecessary.  Please be as deta iled as necessary in your expl anation.  In some of our
comments, we may ask you to provide us w ith information so we may better understand
your disclosure.  After reviewing this info rmation, 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

Notes to the Financial Statements

- General

Mr. Todd Huss
Global Casinos, Inc.
December 5, 2006 Page 2

1. We note from your response to our prior comment 5 that you have modified your
presentation to conform to the guidance in EITF 00-22 and you have disclosed in
the notes to the financial statements th at payouts are included in promotional
allowances and are presented separately as a reduction of casino revenues.  Please
tell us if you have also recorded a liability as of September 30, 2006 for the
estimated obligation that will ultimatel y be owed to th e loyalty program
customers, and if so, the nature of any changes in that liability from June 30, 2006.  Please note that even though you are only obligated to payout once the $1000 threshold is achieved, we believe that a liability should be  recorded for the
estimated obligation at the time the reve nue is recognized a nd the players begin
earning points.  See paragr aph 10 of EITF 00-22.  Also, to the extent that any
liability that has not been recorded is ma terial to the financial statements, please
revise your financial statements to record  the obligation and the offset to revenue.

Form 10-QSB for the quarter ended September 30, 2006

Note 5. Stock Based Compensation

2. We note that during the quarter e nded September 30, 2006 you adopted the
provisions of and account for stock-based compensation in accordance with SFAS No. 123(R).  In future filings, where awards under share-based payment
arrangements with employees are accounted  for under the intrinsic value method
of APB 25 for
any reporting period for which an income statement is presented,
please provide the tabular presentation of the following information that was
required by paragraph 45 of Stat ement 123 for all those periods:
• Net income and basic and dilute d earnings per share as reported
• The share-based employee compensation cost, net of related tax effects,
included in net income as reported
• The share-based employee compensation cost, net of related tax effects,
that would have been included in ne t income if the fair-value-based
method had been applied
• Pro forma net income as if the fai r-value-based method had been applied
to all awards
• Pro forma basic and diluted earnings per share as if the fair-value-based method had been applied to all awards.
Additionally, please include the disclosu res outlined in paragraph A240 of SFAS
No. 123(R) including the method and assu mptions used for determining fair
value.

********

Mr. Todd Huss
Global Casinos, Inc.
December 5, 2006 Page 3

 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