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SEC Comment Letter 0000000000-25-007280 to Bally's Chicago, Inc. (CIK 0001935799)

Bally's Chicago, Inc. (CIK 0001935799)
Date: July 10, 2025 · CIK: 0001935799 · Accession: 0000000000-25-007280

Regulatory Compliance Risk Disclosure Financial Reporting

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File numbers found in text: 333-283772

Date
July 10, 2025
Author
Division of
Form
UPLOAD
Company
Bally's Chicago, Inc. (CIK 0001935799)

Letter

Re: Bally's Chicago, Inc. Amendment No. 8 to Registration Statement on Form S-1 Filed June 23, 2025 File No. 333-283772 Dear Ameet Patel:

July 10, 2025

Ameet Patel Principal Executive Officer Bally's Chicago, Inc. 100 Westminster Street Providence, RI 02903

We have reviewed your amended registration statement and have the following comments.

Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our May 22, 2025 letter.

Amended Registration Statement on Form S-1 Gaming License, page 18

1. We note your amended disclosure in response to prior comment 1 regarding the Illinois Gambling Act. Please revise to discuss the consequences of the change in offering in light of the ownership interest levels set forth in the Act, and address any risks that may arise if the levels are not met. Add risk factor disclosure as applicable. July 10, 2025 Page 2

Please contact Jeffrey Lewis at 202-551-6216 or Shannon Menjivar at 202-551-3856 if you have questions regarding comments on the financial statements and related matters. Please contact Ruairi Regan at 202-551-3269 or Pam Howell at 202-551-3357 with any other questions.

Sincerely,
Division of
Corporation Finance
Office of Real Estate
& Construction
cc: Senet Bishoff, Esq.

Show Raw Text
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<TEXT>
 July 10, 2025

Ameet Patel
Principal Executive Officer
Bally's Chicago, Inc.
100 Westminster Street
Providence, RI 02903

 Re: Bally's Chicago, Inc.
 Amendment No. 8 to
 Registration Statement on Form S-1
 Filed June 23, 2025
 File No. 333-283772
Dear Ameet Patel:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our May 22, 2025
letter.

Amended Registration Statement on Form S-1
Gaming License, page 18

1. We note your amended disclosure in response to prior comment 1 regarding
the
 Illinois Gambling Act. Please revise to discuss the consequences of the
change in
 offering in light of the ownership interest levels set forth in the Act,
and address any
 risks that may arise if the levels are not met. Add risk factor
disclosure as applicable.
 July 10, 2025
Page 2

 Please contact Jeffrey Lewis at 202-551-6216 or Shannon Menjivar at
202-551-3856
if you have questions regarding comments on the financial statements and
related
matters. Please contact Ruairi Regan at 202-551-3269 or Pam Howell at
202-551-3357 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real Estate
& Construction
cc: Senet Bishoff, Esq.
</TEXT>
</DOCUMENT>