SecProbe.io

June 19, 2014

Via Email
Mr. Geoffrey Davis
Chief Financial Officer
Melco Crown Entertainment Limited
36th Floor, The Centrium
60 Wyndham Street
Central, Hong Kong

Re: Melco Crown Entertainment Limited
 Form 20-F
Filed April 15, 2014
File No. 001-33178

Dear Mr. Davis :

We have reviewed your filing an d 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 advising us when you will provide the requested
response.   If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Business Overview, page 54

City of Dreams Manila, page 58

1. You have disclosed that your subsidiary has been granted the exclusive right to manage,
operate and control City of Dreams Manila.  Please elaborate upon the notion of control and
provide yo ur analysis under ASC 810 -10, including the specific rights held by you and the
Philippine Parties.  Tell us how you have determined that you should consolidate this entity.
We note from your disclosure on page 59 that both you and the Philippine Parties are each
responsible for contributing at least US$500 million to the project.  Please address how these
capital contributions from the Philippine Parties affect your analysis.

Geoffrey Davis
Melco Crown Entertainment Limited
June 19, 2014
Page 2

Revenues, page 86

2. We note your disclosure under “Rooms” on page 87.   In futu re Exchange Act periodic
reports, please clarify whether ADR, occupancy rate and REVPAR include or exclude the
impact of promotional allowances and discuss such impact.

Property and Equipment and Other Long -Lived Assets, page 96

3. We note that you capita lize payroll and payroll -benefit related costs during the
development and construction stage of your casino gaming and entertainment resort
facilities.  Please tell us the methodology used to allocate salaries and related personnel
costs to each specific a sset and the amount of payroll that was capitalized or deferred in
the past three years.

Note 2. Summary of Significant Accounting Policies, page F -12

(e) Restricted Cash, page F -13

4. Please quantify the amount of cash that was frozen by the Taiwanese authorities and how this
amount was classified on the statement of cash flows.  In addition, please explain your rights
to this cash and whether you anticipate being able to gain access to the cash in the future.

Note 8. Long -Term Prepayments, Deposits an d Other Assets, page F -25

5. We note that you have approximately $51 million of net receivables from casino
customers that are not expected to be settled within the next year.  Please explain to us in
detail why you believe that these receivables are collect ible, given the nature of the debt
and the fact that they are already over 90 days old.

Note 19. Employee Benefit Plans, page F -59

6. Please disclose the amount of cost recognized for each of your defined contribution plans
for all periods presented in acco rdance with ASC 715 -70-50-1.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act r ules require.   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 responding to our comments, please provide  a written statement from the company
acknowledging that:

Geoffrey Davis
Melco Crown Entertainment Limited
June 19, 2014
Page 3

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

You may contact Kristi Marrone  at (202) 551 -3429  or me at (202) 551 -3486  if you have
questions regarding comments on the financial statements and related matters.  Please contact
Kristina Aberg  at (202) 551 -3404  or Angela McHale a t (202) 551 -3402  with any other questions.

Sincerely,

 /s/ Daniel L. Gordon

Daniel L. Gordon
Branch Chief