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seccommentletterresponse

David T. Morgan  Senior Vice President & Chief Accounting Officer      International Game Technology PLC  10 Finsbury Square, Third Floor  London EC2A 1AF  United Kingdom      VIA EDGAR    December 23, 2024    Division of Corporation Finance  Office of Trade & Services  United States Securities and Exchange Commission  100 F Street, NE  Washington, DC 20549    Re: International Game Technology PLC  Form 20-F for Fiscal Year Ended December 31, 2023  Form 6-K dated November 12, 2024  File No. 001-36906    Ladies & Gentlemen:    We are responding to your comment letter dated December 17, 2024 to Massimiliano Chiara, Executive Vice President  and Chief Financial Officer, Executive Director of International Game Technology PLC (“IGT” or the “Company”)  related to the above referenced Form 6-K.    For ease of reference, we have reproduced your comments in bold text preceding our response.    Form 6-K dated November 12, 2024  Exhibit 99.1  Third Quarter 2024 Financial Highlights, page 3    1. You discuss the changes in adjusted EBITDA and adjusted EBITDA margin in this section and in the "Nine  Months Ended September 30, 2024 Financial Highlights" below without a discussion of the changes in their  most directly comparable GAAP measures. Please revise your disclosure to also discuss the changes in net  income and net income as a percentage of total revenue over the reporting periods. Refer to Item 100(a) of  Regulation G.    Response:    We acknowledge the Staff’s comment and respectfully submit that in future filings the Company will revise its  disclosures to ensure that when presenting information on adjusted EBITDA and adjusted EBITDA margin, we will  also include disclosure and discussion of the changes in net income and net income as a percentage of total revenue  over the reporting periods.    Should you have any questions or further comments regarding this matter, please do not hesitate to contact the  undersigned at (401) 392-5381.    International Game Technology PLC

    /s/ David T. Morgan  David T. Morgan  Senior Vice President & Chief Accounting Officer        cc: Massimiliano Chiara, Executive Vice President & Chief Financial Officer, Executive Director - International  Game Technology PLC  Audit Committee of the International Game Technology PLC Board of Directors  Kevin Twomey, Partner - PricewaterhouseCoopers LLP