SecProbe.io

Mail Stop 3561         January 15, 2010  Via Fax & U.S. Mail

 Mr. Clifford L. Neuman President Global Casinos Inc. 1507 Pine Street Boulder, Colorado 80302

Re: Global Casinos Inc.
 Form 10-K for the year ended June 30, 2009
Filed September 28, 2009
 File No. 0-15415

Dear Mr. Neuman:

We have reviewed your filing and have th e following comments.  We think you should
revise your 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 detailed as necessary in your re sponse.  In some of our
comments, we may ask you to provide us wi th supplemental information so we may
better understand your disclosure.  After reviewing this info rmation, we may or may not
raise additional comments.

Please understand that the purpose of our revi ew 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 on 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 w ill be complied with, or, if certain of the
comments are deemed inappropriate, advise th e staff of your reas on.  Your response
should be submitted in electronic form, under the label “corresp” with a copy to the staff.
Please respond within ten (10) business days.

Mr. Clifford L. Neuman
Global Casinos Inc. January 15, 2010 Page 2  Management’s Discussion and Analysis, page 26

Results of Operations – Year ended June 30, 2009 compared to Year ended June 30,
2008, page 26
Corporate Occupancy, page 30
1. Reference is made to your disclosure that  upon term ination of the Shared Services
Agreement you began to utilized certain office functions and systems managed by
your president and CEO in Boulder, Colora do which as a result have significantly
reduced your corporate office space requirement .  In this regard, please explain to
us and revise your disclosures in future filings to discuss how such utilization of
office functions and systems managed by your president and CEO have been
accounted for within your financial stat ements.  If no accounting was required,
please explain why and tell  us how your treatment complies with the guidance
outlined in SAB Topic 1:B:1.
 Consolidated Statements of Operations, page F-5

2. We note that gains/losses on asset disposals were classif ied as non-operating.
Such gains (losses) on disposals s hould be separately reported in your
consolidated statement of ope rations within operating income (loss).  Refer to the
guidance under paragraph 45 of SFAS No. 144 and footnote 68 of SAB Topic 13.
Please revise your income statement pres entation in future filings accordingly.

Statements of Stockholders’ Equity, page F-6
3. We note that you have presented your Seri es D Preferred Dividends as a reduction
of
 additional paid in capital.  Please note that dividends are typically charged to
retained earnings rather than additional pa id in capital unless legally declared out
of additional paid in capital, even if those earnings are insufficient to cover them.
Please advise or alternatively you may revi se your presentation in future filings
accordingly.

Note 1.  Organization and Summary of Significant Accounting Policies,

Goodwill
4. Given the significance of your goodw ill balance at June 30, 2009 and 2008,
please revise your notes to the consolidat ed financial statem
ents to include an
accounting policy for evaluating the reco verability of goodwill.  Your footnote
should discuss the factors and/or indicators that management reviews in assessing goodwill impairment; when goodwill is tested  for impairment annually; and how
you measure the amount of goodwill impairment loss to be recognized, if any.  Further, your footnote should also specifica lly disclose the level of reporting at
which goodwill is tested (i.e. reporting unit ).  At a minimum, we would expect

Mr. Clifford L. Neuman
Global Casinos Inc. January 15, 2010 Page 3
this to be at the Company’s operating subs idiary level as it appears that discrete
cash flows exist for each of the operating subsidiaries based upon your disclosures
within the Liquidity and Capital Resources  section of MD&A.   As part of your
response, please provide us with your proposed disclosure.
5. Furthermore, please tell us and revise  future filing to disclose when you
perform
ed your most recent goodwill impair ment test.  Tell us whether any of
your reporting units were at risk of failing st ep one of the impairment test (i.e. fair
value was not substantially in excess of carrying value) and if so, please revise
your disclosures in future filing to in clude the following disclosures for each
reporting until that is at risk of failing step one:

• Percentage by which fair value exceeded car rying value as of the date of the most
recent test;
• Amount of goodwill allocated  to the reporting unit;
• Description of the methods and key assumptions used and how the key
assumptions were determined;
• Discussion of the degree of uncertainty associated with the key assumptions; and
• Description of potential events and/or changes in circumstances that could
reasonably be expected to negativ ely affect the key assumptions.
 Note 5.  Commitments and Contingencies, page F-17

6. From the Business section, we note that the Doc Holliday occupies approximately 12,710 square feet of sp
ace under a lease wi th a remaining term of seven years
with no options to renew or extend the lease. The monthly rent is $25,362 plus triple net expenses, subject to a three percent cap on annual increases.  In light of
the materiality of lease expense, advise us and add disclosure  to indicate whether
you are accounting for leases under AS C 840-20-25-1 (SFAS 13) pursuant to
which scheduled rent increases and abatem ents are to be straight-lined over the
life of the lease.  If you have not accounted  for leases as such, please explain why
and the materiality of any amounts involved.
7. Furthermore, in Note 5-Commitments and Contingencies, you indicate that the
lease also provides for a credit against fu ture monthly ren
t payments if the total
building expenses increase by more than 3%  over a base year calculation, and is
calculated in April each year.  In light  of the materiality of the $87,779 credit
available to apply against future mini mum rent payments through July 31, 2010,
please advise us why you believe your treat ment is appropriate and provide us
with the guidance that your relied upon which supports your accounting for these credits.  We may have further comment upon reviewing your response.

Mr. Clifford L. Neuman
Global Casinos Inc. January 15, 2010 Page 4
Note 8.  Consulting Arrangements, page F-8
8. We note that you entered into consulting arrangements some of which have
resulted in
 material expense.  It is unclear from the disclosures whether expense is
recognized when services have been perf ormed, or certain milestones have been
achieved.  Please tell us and add an  accounting policy that describes the
methodology for recognizing consulting expens es.  If expenses have been ratably
recognized over the life of the agreement as  opposed to when services have been
performed or milestones reached, please provide us with your reasons.  We may have further comment upon reviewing your response.

Note 2.  Acquisition, page F-13
9. Please expand your note to describe the f actors that contributed to a purchase
price that resulted in re cognition of goodwill pu
rsuant to paragraph 51b of SFAS
141.

Note 6 – Income Taxes, page F-18
10. Please revise your income tax footnote in futu re filings to di sclose all components
of the net deferred tax asset or liability recognized in the company’s statement of
financial position.  Refer the disclosure  requirements of paragraph 43 of SFAS
No. 109.
 Other

11. We urge all persons who are responsible for the accuracy and adequacy of the
disclosu
re in the filing to be certain that the filing includes all information
required under the Securitie s Exchange Act of 1934 and that they have provided
all information investors require for an informed investment 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 disclosu re 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

Mr. Clifford L. Neuman
Global Casinos Inc. January 15, 2010 Page 5
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 Effie Simpson at (202) 551-3346, or Jean Yu, at (202) 551-3305
if you have questions regarding comments on the financial statements and related
matters.  Please contact the undersigned at (202) 551-3750 with any other questions.

Sincerely,

Linda Cvrkel Branch Chief
Via Fax: Todd Huss, CFO    (303) 449-1045