SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

June 11, 2013

Via E-mail
Mr. Geoffrey Davis
Chief Financial Officer
Melco Crown Entertainment , LTD
36th Floor, The Centrium
60 Wyndham Street
Central, Hong Kong

 RE: Melco Crown Entertainment , LTD
Form 20 -F for the Fiscal Year Ended December 31, 201 2
  Filed April 1 8, 2013
  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 providing the requested
information  or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstance s, please tell us why in your response.

After reviewing the information  you provide in response to these comments, we may
have  additional comments.

Adjusted Property EBITDA and Adjusted EBITDA, page 86

1. Please revise in future filings to include a reconciliation of your non -GAAP measures
Adjusted Property EBITDA and Adjusted EBITDA t o net income.

Investing Activities, page 92

2. Please tell us and clarify in future filings how the total capital expenditures in the table on
page 93 reconcile to the amounts disclosed as capital expenditur es in your discussion of
net cash used in investing activities.

Mr. Geoffrey Davis
Melco Crown Entertainment, LTD
June 11, 2013
Page 2

Consolidated Statements of Cash Flows, page F -8

3. It appears that the line item acquisition of property and equipment includes both the
purchase of assets and costs capitalized in the developm ent of properties.  In future
filings, please present separate line items for acquisitions of property and equipment and
capitalized expenditures.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing inclu des the  information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are respons ible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our commen ts, please provide a written  statement from the company
acknowledging that

 the company is responsible for the adequacy and accuracy of the disclosure in t he 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 federal securities laws of the United States.

You may contact William Demarest, Staff Accountant, at (202) 551 -3432 or me at (202)
551-3694  with any questions .

        Sincerely,

        /s/ Jonathan Wiggins

        Jonathan Wiggins
        Staff Accountant