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CORRESP
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CORRESP

 1177 Avenue of the Americas

 New York, NY
10036

 T 212.715.9100

 F
212.715.8000

 January 16, 2018

 Via
EDGAR and E-mail (pdf)

 Securities and Exchange Commission

Division of Corporate Finance

 100 F. Street, N.E.

Washington, D.C. 20549

Attn:
Tom Kluck

 Legal Branch Chief

Office of Real Estate and Commodities

Re:
VICI Properties Inc.

 File
No. 333-221997

 Ladies and Gentlemen:

Pursuant to discussions with the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission
(the “Commission”), VICI Properties Inc. (the “Company”) hereby submits the proposed offering terms of the initial public offering (the “Offering”), including the bona
fide price range pursuant to Item 501(b)(3) of Regulation S-K, the “Distribution Policy” and the “Selected Historical and Pro Forma Financial Data—Unaudited Pro Forma Combined Condensed
Financial Information.” These pricing terms shall be included in Amendment No. 2 to the Registration Statement on Form S-11, File No. 333-221997 (the
“Registration Statement”) to be filed with the Commission on or about January 22, 2018. The provided terms are a bona fide estimate of the range of the minimum and maximum offering price and the maximum number of
securities to be offered as of January 16, 2018. Should the bona fide estimates of these terms change between today and January 22, 2018, the figures presented in Amendment No. 2 may increase or decrease accordingly.

In the Offering, the Company proposes to sell up to 51,282,051 shares of common stock and up to an additional 7,692,307 shares of common stock pursuant to the
underwriters’ option to purchase additional shares of common stock. The Company proposes to price the Offering with a bona fide price range of $18.50 to $20.50 per share of common stock, with a midpoint of $19.50 per share of common stock. As
discussed with members of the Staff, this range is initially being provided for your consideration by correspondence given the Company’s and the underwriters’ concern regarding providing such information significantly in advance of the
launch of the offering as well as our desire to provide all information necessary for the Staff to complete its review on a timely basis.

 Mr. Tom Kluck

 January 16, 2018

 Additionally, the Company is enclosing its proposed marked copy of those pages of the Registration Statement
that will be affected by the offering terms set forth herein. These marked changes will be incorporated into Amendment No. 2, to be filed with the Commission on or about January 22, 2018.

The Company seeks confirmation from the Staff that it may launch its Offering with the price range specified herein and include such price range in Amendment
No. 2 of the Registration Statement.

 Please do not hesitate to call the undersigned at (212) 715-9216 or
Jordan Rosenbaum at (212) 715-9117 with respect to the foregoing or if any additional supplemental information is required by the Staff.

Sincerely,

 /s/ Todd E. Lenson

Todd E. Lenson

cc:
Rahul Patel, Esq. (Securities and Exchange Commission)

 Edward B. Pitoniak (VICI Properties
Inc.)

 Jordan Rosenbaum, Esq. (Kramer Levin Naftalis & Frankel LLP)

Edward F. Petrosky, Esq. (Sidley Austin LLP)

Bartholomew A. Sheehan, Esq. (Sidley Austin LLP)

 The information contained in this prospectus is not complete and may be changed. We may
not sell these securities until the registration statement filed with the Securities and Exchange Commission is effective. This prospectus is not an offer to sell these securities and it is not soliciting an offer to buy these securities in a
jurisdiction where the offer or sale is not permitted.

 Subject to completion, dated January 16, 2018

 PROSPECTUS

51,282,051 Shares

 VICI Properties Inc.

Common Stock

 This is the initial public
offering of VICI Properties Inc. We are offering 51,282,051 shares of our common stock. We anticipate that the initial public offering price will be between $18.50 and $20.50 per share.

In connection with this offering, we have applied to list our common stock on the New York Stock Exchange (the “NYSE”) under the ticker symbol
“VICI”.

 We intend to elect and qualify to be taxed as a real estate investment trust as defined under Section 856(a) of the Internal
Revenue Code of 1986, as amended (the “Code”), for U.S. Federal income tax purposes. We currently expect such election to be effective commencing with our taxable year ending December 31, 2017. To assist us in qualifying to be taxed
as a REIT, among other purposes, our charter contains certain restrictions relating to the ownership and transfer of our shares and a provision generally restricting stockholders from owning more than 9.8% in value or in number, whichever is more
restrictive, of any class or series of our shares, including if repurchases by us cause a person’s holdings to exceed such limitations. In addition to the restrictions set forth above, our outstanding shares of capital stock are held subject to
applicable gaming laws. Any person owning or controlling at least 5% of the outstanding shares of any class of our capital stock is required to promptly notify us of such person’s identity. See “Description of Capital Stock” for a
detailed description of the ownership and transfer restrictions applicable to our shares.

 Investing in our common stock involves risks. You
should carefully consider the matters described under the caption “Risk Factors” beginning on page 23 of this prospectus.

 Per Share

 Total

 Initial public offering price

$

$

 Underwriting discounts and commissions to be paid by us(1)

$

$

 Proceeds, before expenses, to us

$

$

(1)
We refer you to “Underwriting” beginning on page 191 of this prospectus for additional information regarding underwriting compensation.

The underwriters may also exercise their overallotment option to purchase an additional 7,692,307 shares from us, at the initial public offering price,
less the underwriting discounts, for 30 days after the date of this prospectus.

 NEITHER THE SECURITIES AND EXCHANGE COMMISSION NOR ANY STATE OR
OTHER SECURITIES COMMISSION HAS APPROVED OR DISAPPROVED THESE SECURITIES OR PASSED UPON THE ACCURACY OR ADEQUACY OF THIS PROSPECTUS. ANY REPRESENTATION TO THE CONTRARY IS A CRIMINAL OFFENSE.

The underwriters expect to deliver the shares against payment in New York, New York on
                    , 2018.

 Joint
Book-Running Managers

Morgan Stanley

Goldman Sachs & Co. LLC

BofA Merrill Lynch

 The date of this Prospectus is
                    , 2018.

 PROSPECTUS SUMMARY

This summary highlights information contained elsewhere in this prospectus. It does not contain all of the information that may be
important to you and your investment decision. You should read the following summary, together with the more detailed information and financial statements appearing elsewhere in this prospectus. You should read this entire prospectus carefully,
including the “Risk Factors,” “Management’s Discussion and Analysis of Financial Condition and Results of Operations,” and “Cautionary Note Regarding Forward-Looking Statements” sections and the consolidated and
pro forma financial information and the notes to those financial statements appearing elsewhere in this prospectus before making an investment decision to invest in our common stock.

Except as otherwise indicated or unless the context otherwise requires, all references in this prospectus to “on a pro forma
basis” refers to on a pro forma basis giving effect to the items described in “Selected Historical and Pro Forma Financial Data—Unaudited Pro Forma Combined Condensed Financial Information.”

Unless otherwise indicated, the information contained in this prospectus is as of the date set forth on the cover of this prospectus, is
based on an initial public offering of 51,282,051 shares of our common stock at a price of $19.50 per share, which is the midpoint of the price range set forth on the front cover of this prospectus, and assumes that the underwriters’
overallotment option is not exercised.

 Overview of the Company

We are an owner, acquirer and developer of experiential real estate assets across leading gaming, hospitality, entertainment and leisure
destinations. Our national, geographically diverse portfolio consists of 20 market-leading properties, including Caesars Palace Las Vegas and Harrah’s Las Vegas, two of the most iconic entertainment facilities on the Las Vegas Strip. Our
entertainment facilities are leased to leading brands that seek to drive consumer loyalty and value with guests through superior services, experiences, products and continuous innovation. Across more than 36 million square feet, our
well-maintained properties are located in nine states, contain nearly 14,000 hotel rooms and feature over 150 restaurants, bars and nightclubs. Our portfolio also includes approximately 37 acres of undeveloped land adjacent to the Strip that is
leased to Caesars, which we may look to monetize as appropriate. We also own and operate four championship golf courses located near certain of our properties, two of which are in close proximity to the Las Vegas Strip. As a growth focused public
real estate company, we expect our relationship with our partners will position us for the acquisition of additional properties across leisure and hospitality.

In December 2017, we acquired from an affiliate of Caesars and then leased back the real estate assets of Harrah’s Las Vegas for
approximately $1.14 billion, and we simultaneously sold to Caesars approximately 18.4 acres of undeveloped land located behind the LINQ Hotel & Casino and Harrah’s Las Vegas for $73.6 million. Simultaneous with the
transaction, we entered into a new VICI PropCo credit facility, comprised of a $2.2 billion senior secured Term Loan B Facility and a $400 million senior secured Revolving Credit Facility, and we used the proceeds from the Term Loan B
Facility and drawings under the Revolving Credit Facility to refinance a portion of our outstanding long-term debt. See “—Recent Developments” below.

We believe we have a mutually beneficial relationship with Caesars, a leading owner and operator of gaming, entertainment and leisure
properties. Our long-term triple-net Lease Agreements with subsidiaries of Caesars provide us with a highly predictable revenue stream with embedded growth potential. We believe our geographic diversification
limits the effect of changes in any one market on our overall performance. We are focused on driving long-term total returns through managing assets and allocating capital diligently, maintaining a highly productive tenant base, capitalizing on
strategic development and redevelopment opportunities, and optimizing our capital structure to support opportunistic growth.

 1

 Our portfolio is competitively positioned and well-maintained. Pursuant to the terms of the
Lease Agreements, which require Caesars to invest in our properties, and in line with its commitment to build guest loyalty, we anticipate Caesars will continue to make strategic value-enhancing investments in our properties over time, helping to
maintain their competitive position. In addition, given our scale and deep industry knowledge, we believe we are well-positioned to execute highly complementary single-asset and portfolio acquisitions to augment growth.

We intend to elect and qualify to be taxed as a REIT for U.S. Federal income tax purposes commencing with our taxable year ending
December 31, 2017. We believe our election of REIT status combined with the income generation from the Lease Agreements will enhance our ability to make distributions to our stockholders, providing investors with current income as well as
long-term growth.

 We are one of the largest net lease REITs in the United States with $648.9 million and $862.5 million of
revenue, $439.1 million and $582.5 million of net income and $544.6 million and $724.0 million of Adjusted EBITDA for the nine months ended September 30, 2017 and for the year ended December 31, 2016, respectively, in each
case on a pro forma basis. For a definition of Adjusted EBITDA and a reconciliation to net income, in each case on a pro forma basis, see “—Summary Pro Forma Financial Data.”

Overview of Caesars

 Caesars is a leading
owner and operator of gaming, entertainment and leisure properties. Caesars maintains a diverse brand portfolio with a wide range of options that appeal to a variety of gaming, travel and entertainment consumers. As of September 30, 2017 and
after giving effect to the sale of Harrah’s Las Vegas to us, Caesars operates 48 properties, consisting of 20 owned and operated properties, eight properties that it manages on behalf of third parties and 20 properties that it leases from us.
Caesars or CRC guarantee the lease payment obligations of the properties leased from us. Caesars has a market capitalization in excess of $9 billion as of the date of this prospectus.

For the year ended December 31, 2016, Caesars had net loss attributable to Caesars of approximately $3.6 billion and Adjusted EBITDA of
approximately $1.1 billion and CEOC had net income of approximately $337 million and Adjusted EBITDA of approximately $1.1 billion. For the twelve months ended September 30, 2017, Caesars had net loss attributable to Caesars of approximately
$3.0 billion and Adjusted EBITDA of approximately $1.1 billion and CEOC had net income of approximately $425 million and Adjusted EBITDA of approximately $1.1 billion.

We use Adjusted EBITDA of Caesars and CEOC to evaluate the capacity of Caesars and CEOC to meet their respective obligations under the
Formation Lease Agreements. Such information is not publicly available for the applicable tenant under the HLV Lease Agreement or its guarantor, CRC.

Please see Annex I for reconciliations of net income/(loss) of Caesars and CEOC to Adjusted EBITDA of Caesars and CEOC, respectively, all as
reported by Caesars in its publicly available filings with the SEC.

 Caesars has diverse sources of revenue, with revenues coming from
gaming, food and beverage, hotel operations and from other sources, including entertainment and retail. Caesars has invested significant resources in updating its hotels, with over 50% of its rooms being renovated during the past two years.
Caesars’ properties have been rewarded with 25 TripAdvisor Certificates of Excellence in 2017. Caesars’ pioneering Total Rewards® program is the gaming industry’s first, largest
and most preferred loyalty program. Additionally, Caesars’ entertainment offerings have made it the number three live entertainment promoter worldwide.

 2

 Under the terms of the Lease Agreements, the tenants are responsible for ongoing costs
relating to our properties thereunder, including property taxes, insurance, and maintenance and repair costs. Each Lease Agreement provides for a fixed base rent for the first seven years of the lease term, contributing to the expected stability of
rental revenue. In addition, each Lease Agreement contains a fixed annual rent escalator on the base rent equal to (a) with respect to the Lease Agreements other than the HLV Lease Agreement, the greater of 2% and the increase in the Consumer Price
Index commencing in the second year of the lease with respect to the CPLV Lease Agreement and in the sixth year of the lease with respect to the Non-CPLV Lease Agreement and the Joliet Lease Agreement, and
(b)(i) with respect to the HLV Lease Agreement, 1% commencing in the second year of the lease term and (ii) the greater of 2% and the increase in the Consumer Price Index commencing in the sixth lease year subject to such increase not
resulting in the EBITDAR to rent ratio being less than 1.6 to 1, in which event the increase will be such reduced percentage provided that such reduction shall not result in the base rent being less than the prior year’s rent. The Lease
Agreements provide