June 13, 2006

Via U.S. Mail and Facsimile (323-330-9902)

Steven Lipscomb
President and Chief Executive Officer
WPT Enterprises, Inc.
5700 Wilshire Boulevard, Suite 350
Los Angeles, California 90036

	Re:	WPT Enterprises, Inc.
		Form 10-K for the Fiscal Year Ended January 1, 2006
		Filed March 8, 2006
		File No. 0-50848

Dear Mr. Lipscomb:

      We have limited our review of your Form 10-K for the fiscal
year ended January 1, 2006 to disclosure relating to your contacts
with countries that have been identified as state sponsors of
terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the
Assistant Director group with respect to other issues.  At this
juncture, we are asking you to provide us with supplemental
information, so that we may better understand your disclosure.
Please be as detailed as necessary in your response. After
reviewing
this information, we may raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General
1. We note the disclosure on page 11 of the Form 10-K that you
have
an international television distribution agreement with Alfred
Haber
Distribution, Inc. pursuant to which your television programming
is
telecast to Cuba and Sudan.  Also, you have filed as Exhibit 10.20
an
agreement with Discovery Communications, Inc. by which you license
to
Discovery the rights to telecast your programming to countries
including Cuba, Iran, North Korea, Sudan, and Syria.  Each of
these
named countries is identified as a state sponsor of terrorism by
the
State Department, and is subject to economic sanctions
administered
by the Treasury Department`s Office of Foreign Assets Control
and/or
the Commerce Department`s Bureau of Industry and Security.  Your
Form
10-K does not contain any information regarding contacts with
those
countries.
Please describe to us, in reasonable detail, your previous,
current,
and anticipated operations or other contacts in Cuba, Iran, North
Korea, Sudan, and Syria, whether through direct or indirect
arrangements.  Discuss their materiality to you in light of the
countries` status as state sponsors of terrorism.  Please also
discuss whether the operations or other contacts, per individual
country or in the aggregate, constitute a material investment risk
to
your security holders.  Your response should specify, among other
things, whether you have contacts with any entities controlled by
or
affiliated with the governments of the countries referred to
above.

2. Your materiality analysis should address materiality in
quantitative terms, including the approximate dollar amount of
revenues, assets, and liabilities associated with Cuba, Iran,
North
Korea, Sudan, and Syria.  Please also address materiality in terms
of
qualitative factors that a reasonable investor would deem
important
in making an investment decision, including the potential impact
of
corporate activities upon a company`s reputation and share value.
In
this regard, we note that Arizona and Louisiana have adopted
legislation requiring their state retirement systems to prepare
reports regarding state pension fund assets invested in, and/or
permitting divestment of state pension fund assets from, companies
that do business with countries identified as state sponsors of
terrorism.  The Pennsylvania legislature has adopted a resolution
directing its Legislative Budget and Finance Committee to report
annually to the General Assembly regarding state funds invested in
companies that have ties to terrorist-sponsoring countries.
Florida
requires issuers to disclose in their prospectuses any business
contacts with Cuba or persons located in Cuba.  Illinois, Oregon,
and
New Jersey have adopted, and other states are considering,
legislation prohibiting the investment of certain state assets in,
and/or requiring the divestment of certain state assets from,
companies that do business with Sudan.  Finally, Brown University,
Harvard University, Stanford University, the University of
California
system, and other academic institutions have adopted policies
prohibiting investment in, and/or requiring divestment from,
companies that do business with Sudan.  Your materiality analysis
should address the potential impact of the investor sentiment
evidenced by these actions directed toward companies having
business
contacts with Cuba, Iran, North Korea, Sudan, and Syria.

* * * * *

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Pradip
Bhaumik,
Attorney-Advisor, at (202) 551-3333 if you have any questions
about
the comments or our review.  You may also contact me at (202) 551-
3470.

								Sincerely,



								Cecilia D. Blye, Chief
								Office of Global Security
Risk


cc: 	Larry Spirgel
		Assistant Director
		Division of Corporation Finance

		Kyle Moffat
		Accounting Branch Chief
	Division of Corporation Finance

Steven Lipscomb
WPT Enterprises, Inc.
June 13, 2006
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