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 April 22, 2025

Robert Coldrake
Chief Financial Officer
Flutter Entertainment plc
300 Park Ave South
New York, New York 10010

 Re: Flutter Entertainment plc
 Form 10-K for the Fiscal Year Ended December 31, 2024
 File No. 001-37403
Dear Robert Coldrake:

 We have reviewed your filing and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2024
Management s Discussion and Analysis of Financial Condition and Results of
Operations
Operating Results
Fiscal 2024 Compared to Fiscal 2023, page 80

1. In your discussion of Group and segment results, you cite multiple
factors as
 impacting your results of operations but provide little quantification
of the
 contribution of each factor to the material changes in the various line
items discussed.
 For example, your discussion of Group general and administrative
expenses and your
 discussions of Adjusted EBITDA for each of your segments beginning on
page
 84 refer to various factors; however, you do not quantify the impact of
these
 factors. Where a material change is attributed to two or more factors,
including any
 offsetting factors, please revise to quantify the contribution of each
factor. Refer to
 Item 303(b) of Regulation S-K.
2. We note in your discussion of the changes in income tax benefit(expense)
that the
 movement is partially due to the tax impact of discrete adjustments.
Please tell us
 what those discrete adjustments are and revise in future filings to
discuss and quantify
 any material discrete items that impacted taxes.
 April 22, 2025
Page 2

Consolidated Financial Statements
Note 3. Segments and Disaggregation of Revenue, page 118

3. We note your disclosure on page 158 that effective from the first
quarter of 2025 the
 company will have two reportable segments: U.S. and International.
Please describe
 the organizational and internal reporting changes that led to this
change in reportable
 segments including whether you have two or four operating segments.
Also, please
 address the following:
 If you now have two operating segments, tell us what financial or
other
 information, if any, the CODM receives for UKI, International or
Australia and
 explain how you determined that these geographic markets no longer
meet the
 definition of an operating segment in ASC 280-10-50-1.
 If you continue to have four operating segments but now aggregate
UKI,
 International and Australia into one reportable segment provide us
with a detailed
 analysis explaining how you determined that these operating segments
meet the
 aggregation criteria in ASC 280-10-50-11.

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Please contact Megan Masterson at 202-551-3407 or Christine Dietz at
202-551-3408
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
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