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 June 23, 2025
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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. 7 to

 Registration Statement on Form S-1

 Filed April 23, 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. 8 to Registration
Statement on Form S-1 (the " Amendment No. 8 ") which reflects the Company's responses to the
comment letter received by the Company on May 22, 2025 from the staff (the " Staff ") of the Securities
and Exchange Commission (the " SEC ") regarding the above referenced Amendment No. 7 to Registration Statement
on Form S-1 previously filed by the Company on April 23, 2025 (the " Amendment No. 7 ").

 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. 8 and all references to page numbers in such responses
are to page numbers in Amendment No. 8.

 June 23, 2025

 Page 2

 Amendment No. 7 to Form S-1 filed April 23, 2025

 General

 1. We note your revised disclosure regarding the criteria
 investors are required to meet to participate in this offering. Given that under the Host
 Community Agreement, Bally's Chicago OpCo, as developer, committed that 25% of the project
 equity will be owned by minority individuals and minority-owned and controlled businesses,
 please clarify how you intend to conduct this offering consistent with the terms of the agreement,
 including disclosure of the material risks of non-compliance and providing cross-references
 to the relevant risk factors. Include whether, for example, investors will be required to
 meet certain criteria to participate in this offering or you intend to provide preferential
 allocations to certain investors, including any criteria you will use for such allocations.
 In this regard we note that the subscription agreement continues to require potential purchasers
 to represent that they satisfy the class A qualification criteria, and the amended and restated
 articles of incorporation to be in effect prior to the closing of this offering states that
 class A interests may be issued only to, and registered only in the name of, individuals
 or entities that satisfy the class A qualification criteria. We also note you disclose that
 you intend to provide preferential allocation to Chicago residents and Illinois residents.
 Lastly, please add back the disclosure describing the ownership requirements in the Illinois
 Gambling Act and how you intend to meet those requirements going forward.

 Response :
The Company respectfully acknowledges the Staff's comment and has revised the disclosure on pages 15, 16, 17, 23, 24, 72 and
150 of Amendment No. 8. The Company further advises the Staff that it has revised the subscription agreement and the amended and
restated articles of incorporation to remove class A qualification criteria.

 2. We note the removal of the disclosure from the cover page regarding
 the transfer restrictions defining "permitted transferees." Please revise the
 cover page and the discussion of permitted transferees on page 182 to describe
 the restrictions on transfers, consistent with Section 4.5 of Exhibit 3.2.

 Response: The Company respectfully acknowledges the Staff's
comment and has revised the Exhibit 3.2 to mirror the discussion of "permitted transferees" in Amendment No. 8.

 Legal Proceedings, page 149

 3. We partially reissue 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. We direct your attention to Item 103 of Regulation
 S-K, which allows for the information to be provided by cross-reference to the risk factor
 disclosure.

 Response: The Company respectfully acknowledges the Staff's
comment and has revised the disclosure on pages 85 and 157 of Amendment No. 8.

 * * *

 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.

 June 23, 2025

 Page 3

 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