SecProbe.io

CORRESP
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    Unassociated Document

              October
      30, 2009

              Paul
      D. Chestovich

              Direct
      Phone: (612) 672-8305

              Direct
      Fax: (612) 642-8305

              Paul.Chestovich@maslon.com

    Via
EDGAR and Federal Express

    Mr. David
R. Humphrey, Branch Chief

    Securities
and Exchange Commission

    100 F
Street, N.E.

    Washington,
DC 20549-3651

              Re:

              Poker
      Magic, Inc. (the “Company”)

              Supplemental
      response letter dated October 12, 2009 regarding the Form 10-K for the
      year ended December 31, 2008

              File
      No. 0-53045

    Dear Mr. Humphrey:

    On behalf
of Poker Magic, Inc., this letter responds to your letter dated October 26,
2009.  The numbered paragraphs in this response letter correspond to
the numbered paragraphs of your letter of October 26, 2009.  For ease
of reference, the Staff’s comments appear in bold immediately preceding the
Company’s responses.  In addition, we are filing amendments to each of
the subject reports as explained below (i.e., Annual Report on Form 10-K for the
year ended December 31, 2008, and Quarterly Reports on Form 10-Q for the periods
ended March 31 and June 30, 2009).

    Form 10-K (Fiscal Year Ended
December 31, 2008)

    General

              1.

              Notwithstanding
      the following comments shown below that request future filing disclosure
      and supplemental information, we note from your response letter to us
      dated October 12, 2009 that you propose future filing disclosure with
      respect to our prior comment numbers 6, 7, 12, and 14, and that you will
      amend the December 31, 2008 Annual Report on Form 10-K and March 31,
      2009 and June 30, 2009 Quarterly Reports on Forms 10-Q with respect to our
      prior comments 10 and 11.  Please note that we have no
      additional comments with respect to your response to our prior comments 1
      through 4, 9 and 13.

    RESPONSE:

    We agree
with your characterization, and are submitting amendments to the reports you
refer to above.

    Mr. David
R. Humphrey, Branch Chief

    October
30, 2009

    Page
2

    Management’s Discussion and
Analysis

    Results of Operations, page
13

              2.

              We
      have reviewed your response to our prior comment 5.  We suggest
      you expand the narrative disclosure to also reconcile with the amounts
      shown in the table on page 13 for the line items “Consulting Expenses” and
      “Executive Management Compensation” as your current discussion of these
      costs do not appear to be solely included within these two line items but,
      as the last sentence of your response indicates, spread among other line
      items within the table.  In this regard, you may, for example,
      include the next to the last sentence of your response as it relates to
      the components of the tabular line item “Executive Management
      Compensation.”  Also, given that the tabular line item
      “Consulting Expenses” shows amounts substantially lower than the amounts
      shown in narrative discussion, we believe it would [be] useful to the
      reader to reconcile or account for this difference in each period
      presented.  Please revise in future
  filings.

    RESPONSE:

    As you
request, we will expand the narrative disclosure in our future quarterly and
annual reports to ensure that the amounts discussed in the narrative reconcile
with the amounts shown in similar tables.

    *   *   *   *

    As you
requested, on behalf of the Company, the Company acknowledges as
follows:

    [1] the
Company is responsible for the adequacy and accuracy of the disclosure in the
filing;

    [2] 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

    [3] 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.

    Mr. David
R. Humphrey, Branch Chief

    October
30, 2009

    Page
3

    Please do
not hesitate to contact me at (612) 672-8305 with any questions concerning the
Company’s responses or the accompanying amendments.

              Very
      truly yours,

              /s/
      Paul Chestovich

              Paul
      D. Chestovich

    Enclosures

                cc:

      Joseph A. Geraci, II (w/o
enclosures)

              Douglas
      Polinsky (w/o enclosures)

              Rachel
      Polson (w/o enclosures)

              Abigail
      Grenfell (w/o enclosures)