SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

 June 14, 2011
 Via Facsimile

Mr. Geoffrey Davis Chief Financial Officer Melco Crown Entertainment LTD 36
th Floor, The Centrium
60 Wyndham Street Central, Hong Kong   RE:  Melco Crown Entertainment LTD
Form 20-F for the Fiscal Ye ar Ended December 31, 2010
  Filed April 1, 2011
  File No. 1-33178

Dear Mr. Davis:
We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.    Item 4.  Information on the Company

 B.  Business Overview, page 34

1. In future Exchange Act periodic reports, please discuss your arrang ements with junket
operators in greater detail, including more  information on your specific commissions as
well as credit risks arising from the extension of  credit to junkets.  Please also supplement
your disclosure in the MD&A to discuss the percentage of your VIP customer revenues
which are derived from these arrangements.

Mr. Geoffrey Davis
Melco Crown Entertainment LTD June 14, 2011 Page 2
 Item 5.  Operating and Financial Review and Prospects

 A.  Operating Results

 Critical Accounting Policies and Estimates, page 61

2. In future filings, please include a critical  accounting policy and a significant accounting
policy that clearly describes your cap italization policy as  it relates to
construction/development costs including intere st, salaries and G&A,  real estate taxes
and any other significant amounts that are cap italized during the pre-acquisition phase
and the construction phase.  For the deve lopment phase, discuss the periods of
capitalization including a discussion of when the cap italization period ends.
3. In future periodic filings, please revise to in clude an analysis of your capital expenditures
by disclosing total capital expenditures for new development, redevelopment/renovations,
and other capital expenditures by year. In a ddition, please provide a narrative discussion
of significant changes in capital  expenditures from year to ye ar and of expectations for
the future.
4. Clarify to us the amount of soft costs such  as payroll and other G&A costs capitalized
during 2010.

B. Liquidity and Capital Resources

Description of our Indebtedness
 Sources and Uses, page 73

5. In future Exchange Act periodic reports, please supplement your discussion of sources of
cash with a discussion of anticipated cash uses  for the next fiscal year, including debt
payments, interest payments, capital expenditu res and anticipated development costs.

D. Trend Information, page 74
6. In future Exchange Act periodic report s, please revise your narrative under this
subheading to provide more detailed disclosu re regarding the prosp ective impact of the
proposed smoking ban legislation.  Please also supplement your disclosure to discuss the
potential of tightened liquidity in China a nd cooling measures being implemented by the
banking system in Chinese markets, to the extent material.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy

Mr. Geoffrey Davis
Melco Crown Entertainment LTD June 14, 2011 Page 3
 and adequacy of the disclosures they have made.
  In responding to our comments, please provi de a written statement from the company
acknowledging that
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure 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 proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact William Demarest, Staff Acco untant, at (202) 551-3432 or me at (202)
551-3486 with any questions on the financial statemen ts or related matters.  Please contact Jerard
Gibson, Staff Attorney at (202) 551- 3473 with any other questions.
         S i n c e r e l y ,           /s/ Daniel L. Gordon          Daniel L. Gordon         B r a n c h  C h i e f