SecProbe.io

Mail Stop 3720

October 27, 2017

Daniel B. Silvers
Chief Executive Officer and Director
Leisure Acquisition Corp.
250 West 57th Street, Suite 2223
New York, NY 10107

Re: Leisure Acquisition Corp.
Draft Registration Statement on Form S -1
Submitted October 3, 2017
  CIK No. 0001716947

Dear Mr. Silvers :

We have reviewed your draft registration statement  and 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 by providing the requested information and either submitting
an amended draft registration statement or  publicly  filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circu mstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing the information you provide in response to these  comments  and your
amended draft registration statement or filed registration statement,  we may have  additional
comments.

General

1. Please supplementally provide us with copies of all written communications, as defined
in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your
behalf, present to potential investors in rel iance on Section 5(d) of the Securities Act,
whether or not they retain copies of the communications.

2. Please submit all exhibits as soon as possible, particularly the form of amended and
restated certificate of incorporation.

Daniel B. Silvers
Leisure Acqui sition Corp.
October 27, 2017
Page 2

 Summary

Our Company, pa ge 2

3. Consider including an explanation of how the Company defines leisure -related businesses
and/or examples of the types of companies that management views as operating under the
umbrella of the “leisure -related” sector.

4. Please revise to include more pr ominent disclosure cautioning potential investors against
relying on assertions about Mr. Weil’s and Mr. Silver’s past performance, particularly
with respect to Mr. Weil’s involvement with two successor entities of blank check
companies, as indicative of f uture performance of Leisure Acquisition Corp.

Our Sponsorship, page 5

5. We note your statement that your management team has “significant experience in
identifying businesses with opportunities to accelerate organic growth and/or add on
attractive acquisi tion targets.”  Please briefly describe in more detail the background for
this statement, including management’s prior and/or current roles at Scientific Games,
Inspired Entertainment, and the various investment banking, management consulting, and
board s ervice roles that you refer to.

6. It appears certain of your directors, officers, and sponsors have been involved with other
special purpose acquisition companies (SPACs).  Disclose here and on page 79 the names
of all such SPACs and discuss briefly any acqu isitions made by those SPACs, the current
trading markets of the applicable post -business combination entities, and the benefits
received by the control persons from their respective as sociation with those entities.

7. We note your disclosure that Hydra Mana gement and Matthews Lane Capital Partners
have partnered together on “numerous efforts.”  Please describe in greater detail the
history of that relationship and provide substantive examples of the prior ventures.

The Offering, page 10

8. We note the redemption feature of the public warrants whereby the company may redeem
the public warrants for common stock based upon the “fair market value” of the common
stock.  Please disclose here and in the description of the public warrants on page 117 the
purpos e and effect of this redemption feature and that this redemption feature differs
from warrant redemption features used in other blank check offerings.  Disclose when
and why the company would redeem the public warrants in this manner.  Explain how the
“redemption price” will be determined.  Provide an example to illustrate the operation of
the redemption feature.

Daniel B. Silvers
Leisure Acqui sition Corp.
October 27, 2017
Page 3

 9. We note that you have 27 months, including the three month extension period, within
which to complete the initial business combination and that t he extension period is
applicable only if the Company has executed a letter of intent for a business combination
within 24 months from the closing of this offering.  Please disclose whether the Company
may seek to amend its amended and restated certificate  of incorporation to extend the
date by which it must consummate a business combination should the Company require
time beyond the 27 months.

Risk Factors

Our public stockholders may not be afforded an opportunity to vote on our proposed business
combina tion, which means we may complete our initial business combination even though a
majority of our public stockholders do not support such a combination, page 29

10. We note your disclosure that there are certain circumstances which, if occurring, may not
requi re you to seek stockholder approval of a future business combination.  Please
enhance your disclosure to include greater detail about the factors you will consider when
determining whether to seek stockholder  approval in those instances where you would
not be statutorily required to do so.  Explain, for example, how the timing of a proposed
transaction would weigh for or against seeking shareholder approval.

Our stockholders may be held liable for cla ims by third parties against us  to the extent of
distrib utions received by them upon redemption of their shares, page 39

11. Disclose here that due to the Company’s intention to comply with the procedures set forth
in Section 281(b) of the Delaware General Corporation Law, stockholders will not know
at the time of  dissolution the scope of potential claims against you.

Management

Conflicts of Interest, page 105

12. We note your disclosure that your officers and directors may have a conflict of interest
with respect to evaluating a particular business combination if t he retention or resignation
of any such officers and directors were to be included by a target business as a condition
to any agreement with respect to your initial business combination.  Discuss here and in
the summary whether management expects to contin ue with the company following
consummation of a business combination.  Similarly, address how the company intends
to balance the prospect of a given transaction and its merits with the possible expectation
of management seeking to enter into employment con tracts with a target.

Daniel B. Silvers
Leisure Acqui sition Corp.
October 27, 2017
Page 4

 13. Please specifically address the other blank check offerings that management is currently
involved in.  Discuss in greater detail the risk of conflicts and competition between these
entities and management, and state whether managem ent will have procedures in place to
resolve conflicts of interest.

14. We note your disclosure that each of your officers and directors presently has “additional,
fiduciary or contractual obligations to other entities pursuant to which such officer or
direct or is or will be required to present a business combination opportunity.”  Please
discuss in greater detail the nature of these obligations, the type of entities to which your
officers or directors owe these fiduciary or contractual obligations, the number  of such
entities, and whether scenarios could arise whereby business opportunities may be
provided to one of the other entities instead of to Leisure Acquisition Corp.

You may contact Joseph Kempf , Senior Staff Accountant  at (202) 551 -3352  or Robert S.
Littlepage, Accountant Branch Chief at (202) 551 -3361 if you have questions regarding
comments on the financial statements and related matters.  Please contact Joshua Shainess,
Attorney -Adviser  at (202) 551 -7951, Celeste M. Murphy , Legal Branch Chief  at (202) 551 -3257,
or me at (202) 551 -3810 with any other questions.

Sincerely,

 /s/ Celeste M. Murphy for

 Larry Spirgel
Assistant Director
AD Office 11 – Telecommunications