Securities Exchange Act of 1934
Section 13

October 18, 2010

RESPONSE OF THE OFFICE OF INTERNATIONAL CORPORATE FINANCE
DIVISION OF CORPORATION FINANCE

Based on the facts presented, the Division's views are as follows. Capitalized terms have the same meanings defined in your letter.

The Division will not object if Melco Crown Gaming (Macau) Limited, the Macau subsidiary of Melco Crown Entertainment Limited, is treated as a 100%-owned subsidiary for the purposes of Rule 3-10 of Regulation S-X. We note in particular that the non-parent company ownership for Melco Crown Gaming (Macau) Limited is at the minimum level required to comply with Macau law.

This position is based on the representations made to the Division in your letter. Different facts or conditions might require a different result. Further, this letter only expresses the Division's position on enforcement and does not purport to express any legal conclusions on the question presented.

Incoming Letter:

The Incoming Letter is in Acrobat format.

http://www.sec.gov/divisions/corpfin/cf-noaction/2010/melcocrown101810-13.htm