SecProbe.io

May 20, 2008  Mail Stop 4561
By U.S. Mail and facsimile to (852) 2537-3618

Mr. Lawrence Ho, Chief Executive Officer Melco PBL Entertainment (Macau) Limited 36
th Floor, The Centrium
60 Wyndham Street Central  Hong Kong
RE: Melco PBL Entertainment (Macau) Limited
            File No.  001-33178
 Form 20-F for the year ended December 31, 2007

Dear Mr. Ho:
We have reviewed the above referenced filing and have the following comments.
We have limited our review to only your fina ncial statements and related disclosures and
will make no further review of your documents.  As such, all persons who are responsible for the adequacy and accuracy of the disclosu res are urged to be certain that they have
included all information required pursuant to  the Securities Exchange Act of 1934.

We think you should address these comments in future filings.  Please confirm in
writing that you will do so and also explai n to us how you intend to comply. If you
disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary.  Please be as detailed as necessary  in your explanation.  After
reviewing your explanation, we may or  may not 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 comment or on any other aspect of
our review.  Feel free to call us at the tele phone numbers listed at th e end of th is letter.

Form 20-F

Selected Financial Data, page 5

1. With respect to your presentation of Op erating/Adjusted EBITDA in Selected
Financial Data, please include a cross re ference in this se ction to your SFAS 131

Melco PBL Entertainment (Macau) Limited
Page 2 of 3
information disclosed in the notes to your financial statements. Also, reconcile the
measure presented in this section for 2006 to  the measure presented in the notes to
your financial statements. Refer to Question 19 of the Frequently Asked Questions Regarding the Use of Non-GAAP Financial.
 Certifications, Exhibit 12.1 and 12.2

 2. We noted that the identification of the certifying indivi dual at the beginning of the
certifications required by Exchange Act Ru le 13a-14(a) also in cludes the title of
the certifying individual. Considering that  these certifications must be signed in a
personal capacity, please confirm to us  that your officers signed such
certifications in a personal capacity and th at you will revise your certifications in
future filings to exclude the title of the certifying individual from the opening sentence.

As appropriate, please respond to our commen ts within 10 business days or tell us
when you will provide us with a response.  Please submit your letter on EDGAR. Please
understand that we may have additional comm ents after reviewing your response to our
comments.   We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed 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
filings;

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities 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 filings or in response to our comments on your filings.

Melco PBL Entertainment (Macau) Limited
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 You may contact Jorge L. Bonilla at ( 202) 551-3414 or me at (202) 551-3498 if
you have any questions,                                                                                      Sincerely,                                                                                                                                                                                                                                                                          Linda van Doorn                                                                                   Senior Assistant Chief Accountant