SecProbe.io

Mail Stop 3561         March 22, 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 response letter dated February 26, 2010 in response to our letter
dated January 15, 2010, and have the following additional comments.

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.  Statements of Stockholders’ Equity, page F-6

1. We note your response to pr evious comment number 3, a nd reissue the comm ent.
As discussed telephonically with Mr . Huss, pursuant to ASC Topic 505-10,
dividends are typically charge d to retained earnings rather than additional paid in
capital unless legally declared out of add itional paid in capital, even if those
earnings are insufficient to co ver them.  Please revise your  presentation in future
filings or advise us of how your pr esentation complies with the guidance
prescribed in ASC Topic 505-10.
 Note 1.  Organization and Summary of Significant Accounting Policies,

 Goodwill

2. We note your response to previous numb er four.  As discussed telephonically
with Mr. Huss, the disclosure should i ndicate that goodwill is considered impaired

Mr. Clifford L. Neuman
Global Casinos Inc. March 22, 2010 Page 2
if the implied fair value of goodwill is less than the carrying value of goodwill
and is determined through a two-step process as outlined in ASC 350.  Please expand your disclosure to describe the tw o-step process involv ed in determining
whether goodwill impairment exists (i.e. step one - if FV of reporting unit is less than carrying value of reporting unit incl uding goodwill then step two is required,
which involves assigning the fair valu e of the reporting unit to the asset and
liabilities of the reporting unit sim ilar to a purchase price allocation).
Furthermore, although you indicate the methods  used to determine the fair value
of goodwill, your current disclosure states  that "The fair value of goodwill has
been determined from time-to-time using the discounted future cash flow method,
the cost and market approach obtained by independent appraisal, or a combination
thereof" which implies that impairment is being measured directly using one of the methods described, which is not appropriate.  Please revise your disclosure in future filings to incorporate the aforementioned considerations and provide us with your proposed disclosure.  We ma y have further comment upon reviewing
your response.
3. We note your response to our prior comment  number five.  Please clarify for us

and revise your notes to the consolidated financial statements to specifically state the level at which the company determines  to be its reportin g units (e.g. operating
subsidiaries).  Furthermore, we note that you indicate that the most recent goodwill impairment test for the Doc Hollid ay Casino reporting unit as of June
30, 2009 resulted in a fair value significantly in excess of carrying value.  In this
regard, please specifically tell us in your next response the percentage for which
the fair value the Doc Holliday reporting unit exceeded its carry value at June 30, 2009.
4. Furthermore, although you performed your mo st recent im
 pairment analysis on
June 30, 2009, we note that based on the r ecent trading price of your common
stock, the net book value of your Company is  approximately 22% in excess of its
market capitalization and within the Li quidity and Capital Resources of your
Form 10-Q for the interim period e nded December 31, 2009 you indicate that
even though cash flows from Bull Durham have been sufficient to fund operations, cash flows from Doc Holliday have not been sufficient to fund its
operations and necessary capital improvements.  Furthermore, it appears that although you have implemented operating changes since its acquisition in March
2008, cash flows for Doc Holliday are only near  break-even and lastly, as all debt
renegotiations still remain in progress, all de bt balances are classified as current.
In this regard, it appears that an interi m goodwill impairment analysis pursuant to
ASC Topic 350-20-35-30 may be required in light of the aforementioned negative
factors.  Tell us whether you have performed an interim impairment analysis as of
December 31, 2009 and if so, provide us with the results, including a discussion of any significant changes made to your assumptions, or lack thereof, which
would be helpful with providing us th e proper context for understanding your
impairment analysis.  If an updated im pairment analysis was not performed,

Mr. Clifford L. Neuman
Global Casinos Inc. March 22, 2010 Page 3
please explain in detail as to why given the adverse facts and circumstances noted
above.  We may have further co mment upon reviewing your response.
 Note 5.  Commitments and Contingencies, page F-17

5. We note your response to pr evious comment #7.  In light of the m ateriality of the
amounts and the estimates involved, please expand your disclosure to include the
information  provided in your response.
 Form 10-Q for the quarter ended December 31, 2009

 Note 3.  Loan Participation Obligations, page 16

6. Reference is made to your disclosure re garding the Loan Docum ent Purchase and
Assignment Agreement with the holder of  the senior mortgage of the Bull
Durham Casino in which the Company obtained all of the rights, title and interest in and to the Note and Loan Agreement.  Reference is also made to Loan Participation Agreement whereby the Co mpany assigned to an unaffiliated third
party and director in th e note for total consideration of $265,000 and a loan
participation fee of 53,000 shares of the Company’s common stock.  Please
explain in greater detail the nature and substance of this  transaction including how
such transaction has been recorded with in your financial statements.  Please
elaborate on your statement that “The re maining undivided 63.22% interest in the
Note owned by the Company continues to  be in technical default, but is
eliminated on consolidation for accounting purposes.”  It is unclear to us why
such amounts have been eliminated if the Company continues to be in technical default.  Furthermore, pleas explain to us whether the Loan Participation
Agreement with the unaffiliated third part y and director of the company totaling
$265,000 represents a partial refinancing of the loan arrangement and if so, why it
appears that the entire lo an participation fee (i.e. 53,000 shares of the company’s
common stock) incurred as part of the loan financing arrangement was expensed
in the period the ar rangement was consummated.  As pa rt of your response, please
provide us with the guidance you relied  upon in determining your accounting
treatment for this transa ction.  We may have further comment upon receipt of
your response.
 Note 5.  Commitments and Contingencies, page 19

Leases, page 19
7. We note from your disclosure on page 20 that on January 29, 2010 the landlord of
the Doc H
olliday Casino property agreed to a rent abatement in the total
aggregate amount of $40,000 prorated ove r a six month term I the amount of
$6,667 per month beginning in February, 2010 and continuing through July 2010.
 In this regard, please tell us your accounting treatment for the rent abatement and
how your treatment complies with the guidance prescr ibed in ASC Topic 840-20-

Mr. Clifford L. Neuman
Global Casinos Inc. March 22, 2010 Page 4
25-6.

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