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United States securities and exchange commission logo
May 27, 2021
Bret Yunker
Chief Financial Officer
Caesars Entertainment, Inc.
100 West Liberty Street, 12th Floor
Reno, NV 89501
Re: Caesars
Entertainment, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed March 1, 2021
File No. 001-36629
Dear Mr. Yunker:
We have reviewed your May 17, 2021 response to our comment
letter and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.
Please respond to the comment 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 our
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to the comment, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
May 4, 2021 letter.
Form 10-K for the Fiscal Year Ended December 31, 2020
Management's Discussion and Analysis of Financial Condition and Results
of Operations,
Key Performance Metrics, page 36
1. We note your response
to prior comment 1. You state that you believe the quantification
and disclosure of key
performance indicators would not have provided information helpful
in understanding your
operating trends and results, due to the material adverse impact of
COVID-19 on and
inclusion of Caesars Entertainment Corporation s operations from date
of merger in your 2020
results. However, we note that the quantification of such material
effects due to known
trends and uncertainties can also provide readers a better
understanding of those
effects and their importance. In addition, we note that
performance metrics can
allow management to share with investors how management is
analyzing the current
and potential impact of COVID-19 on the company's operating
Bret Yunker
Caesars Entertainment, Inc.
May 27, 2021
Page 2
results. In this regard, explain further why you believe it is not
necessary to provide
quantified key performance metrics for 2020 and 2019 along with
relevant discussion
explaining the year-over-year variances in these metrics. We refer you
to Section III.B.1
and B.3 of SEC Release No. 33-8350 and CF Disclosure Guidance: Topics
No. 9 and 9A.
You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or
Jennifer Monick,
Assistant Chief Accountant at (202) 551-3295 if you have questions.
FirstName LastNameBret Yunker Sincerely,
Comapany NameCaesars Entertainment, Inc.
Division of
Corporation Finance
May 27, 2021 Page 2 Office of Real
Estate & Construction
FirstName LastName