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May 30, 2024
Marcus Glover
Chief Financial Officer
Bally's Corporation
100 Westminster Street
Providence, RI 02903
Re:Bally's Corporation
Form 10-K for the year ended December 31, 2023
File No. 001-38850
Dear Marcus Glover:
            We have limited our review of your filing to the financial statements and related
disclosures 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 year ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 43
1.We note you have identified multiple factors that impact your operating results but it does
not appear that you have separately quantified each factor. For example purposes only,
you state that gaming revenue increased due to organic growth, recent acquisitions and a
newly opened temporary casino. When there are multiple factors impacting your operating
results, please revise your disclosures to separately quantify the impact from each factor.

Notes to Consolidated Financial Statements
10. Goodwill and Intangible Assets, page 87
2.We note your disclosure of certain items that are valued on a recurring and non-recurring
basis that have utilized level 3 inputs. We note you have provided quantitative information
about the significant unobservable inputs for Sinclair Performance Warrants, however, it
does not appear that you have provided such quantitative information for other items (e.g.,

 FirstName LastNameMarcus Glover
 Comapany NameBally's Corporation
 May 30, 2024 Page 2
 FirstName LastName
Marcus Glover
Bally's Corporation
May 30, 2024
Page 2
a trademark within the International Interactive segment resulting in impairment in 2023,
contingent consideration) that you have identified as utilizing level 3 inputs. Please tell us
how you determined it was unnecessary to disclose quantitative information about the
significant unobservable inputs for such items in accordance with ASC 820-10-50-2(bbb).
3.Please clarify for us the level of the fair value hierarchy within which the fair value
measurements are categorized in their entirety (Level 1, 2, or 3) for the three gaming
licenses within the Casinos & Resorts segment that resulted in impairment during 2023
and the indefinite lived trademark within the International Interactive segment that
resulted in impairment in 2022. Please tell us how you complied with ASC 820-10-50-
2(b) or tell us how you determined the disclosure of the level is not necessary. To the
extent such items were valued using level 3 inputs, please tell us how you determined it
was unnecessary to disclose quantitative information about the significant unobservable
inputs for such items in accordance with ASC 820-10-50-2(bbb).
            In closing, 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 Howard Efron at 202-551-3439 or Jennifer Monick at 202-551-3295 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction