SecProbe.io

Mail Stop 3561
        December 21, 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 December 15, 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 21, 2006 Page 2

1. We note from your response to our prior co mment 1 that no liability was recorded
at June 30, 2006 because the financial eff ect at June 30, 2006 was deemed to be
immaterial.  Please tell us the amount of  the liability that would have been
recorded as of June 30, 2006 if you had accounted for the Sharpshooters Club in
accordance with EITF 00-22 for the year ended June 30, 2006.  If the amount is
material to the financial statements at June 30, 2006, please tell us why you believe the change in accounting for the Sharpshooter’s Club liability should be accounted for as a change in estimate versus a correction of  an error.  Please note
that even though you changed your methodol ogy for analyzing and recording the
activity in the Sharpshooter s club in the first quarter of fiscal year 2007, we
believe that a liability should be recorded as of June 30, 2006 for the estimated obligation at the time the revenue is r ecognized and the play ers begin earning
points.  See paragraph 10 of EITF 00-22.

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 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