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    April 22, 2025

    1271 Avenue of the Americas

    New York, New York 10020-1401

    Tel: +1.212.906.1200 Fax: +1.212.751.4864

    www.lw.com

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VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-6010

  Attention:
  Jeffrey Lewis

Shannon Menjivar

Ruairi Regan

Pam Howell

Re: Bally’s Chicago, Inc.

Amendment No. 6 to

Registration Statement on Form S-1

Filed February 12, 2025

File No. 333-283772

Ladies and Gentlemen:

On behalf of Bally’s Chicago, Inc. (the
“Company”), we submit this letter in connection with the filing of Amendment No. 7 to Registration Statement
on Form S-1 (the “Amendment No. 7”) which reflects the Company’s responses to the comment letter
received by the Company on February 14, 2025 from the staff (the “Staff”) of the Securities and Exchange
Commission (the “SEC”) regarding the above referenced Amendment No. 6 to Registration Statement on Form S-1
previously filed by the Company on February 12, 2025 (the “Amendment No. 6”).

For ease of review, we have set forth below each
of the numbered comments of your letter in bold type followed by the Company’s responses thereto. Unless otherwise indicated, capitalized
terms used herein have the meanings assigned to them in Amendment No. 7 and all references to page numbers in such responses
are to page numbers in Amendment No. 7.

January 29, 2025

Page 2

Amendment No. 6 to Form S-1 filed February 12,
2025

General

 1. Please expand your disclosure in response to prior comment 1 to address clearly whether you are in compliance with the terms of
the Host Community Agreement and to the extent you are not in compliance, the consequences of such non-compliance. Also, clarify how the
inability to raise the full amount in this offering and additional funding by Bally’s Chicago HoldCo would impact compliance with
the Host Community Agreement and any associated risks. In this regard we note that the agreement specifically states “Developer
commits that 25% of the Project equity will be owned by Minority individuals and Minority-Owned and Controlled Businesses no later than
twelve months following commencement of the Term or such later date as may be determined by the City, and will continue for no less than
five years thereafter.”

Response:
The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 14, 15, and 22 of Amendment
No. 7 to address Bally’s compliance with the Host Community Agreement and ongoing discussions with the City of Chicago.

Legal Proceedings, page 155

 2. We note your disclosure added in response to prior comment 2. Please revise to address specifically any impact on the investors
in this offering that may result from the potential outcomes of the litigation. Please ensure your disclosure addresses potential outcomes
that may occur either before or after the closing of the offering. Where you discuss the possibility that you could be found liable for
monetary damages, please expand to indicate whether this could include punitive damages. Disclose the specific consequences to you and
your investors in the event the litigation results in the Host Community Agreement being modified or terminated, any impact on the status
of your casino license, and any impact on your ability to operate. Please also address whether there are any limitations on enforcement
of the Host Community Agreement. Finally, revise the risk factors on pages 64 and 84 including the headings to those risk factors
to reflect that you are currently in litigation and for consistency.

Response:
The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 65, 85 and 86 of Amendment
No. 7.

* * *

We hope the foregoing answers are responsive to
your comments. Please do not hesitate to contact me by telephone at (212) 906-1834 with any questions or comments regarding this correspondence.

    Very truly yours,

    /s/ Senet Bischoff

    Senet Bischoff

    of LATHAM & WATKINS LLP

    cc:
    (via email)

    Ameet Patel, Bally’s Chicago, Inc.

    Sony Ben-Moshe, Esq., Latham & Watkins LLP

    John Slater, Esq., Latham & Watkins LLP