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                               October 26, 2021

       Randy Hyzak
       Chief Financial Officer
       LAS VEGAS SANDS CORP
       3355 Las Vegas Boulevard South
       Las Vegas, Nevada 89109

                                                        Re: LAS VEGAS SANDS
CORP
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Response dated
September 29, 2021
                                                            File No. 001-32373

       Dear Mr. Hyzak:

              We have reviewed your September 29, 2021 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments 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
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       September 15, 2021 letter.

       Form 10-K for the Fiscal Year Ended December 31, 2020

       General

   1.                                                   You state in response
to prior comment 2 that your capital expenditures regarding climate-
                                                        related initiatives are
primarily focused on energy and water efficiency projects and that
                                                        your climate-related
program costs related to these initiatives primarily consist of payroll
                                                        and third-party
consultant costs. You further state that these capital expenditures and
                                                        program costs were
immaterial during the three years ended December 31, 2020. Please
                                                        tell us more about
physical changes you are making, such as the installation of building
                                                        system technology to
monitor and help reduce consumption, and whether you consider the
                                                        related costs to be
part of your capital expenditures for climate-related initiatives. Include
                                                        information quantifying
your capital expenditures and program costs and explain how you
 Randy Hyzak
FirstName LastNameRandy
LAS VEGAS     SANDS CORPHyzak
Comapany
October 26,NameLAS
            2021    VEGAS SANDS CORP
October
Page 2 26, 2021 Page 2
FirstName LastName
         determined they were not material. In addition, tell us about any
compliance costs you
         have incurred related to climate change.

2.       In your response to prior comment 3 you state that you experienced
physical damage to
         your properties and temporary loss of business from several typhoons
and that you do not
         consider these events to be material. Please provide more detail about
and quantify the
         property damage and the loss of business you experienced and explain
how you
         determined they were not material. In addition, tell us how you
considered how indirect
         weather-related impacts may affect your customers and suppliers.
3.       You also state in your response to prior comment 3 that you are
exposed to potentially
         significant losses resulting from catastrophic events and severe
weather conditions, which
         could be the result of climate change among other factors. However,
the risk factors you
         cite in support of this statement appear to address natural disasters
and weather conditions,
         not the risk of the significant physical effects of climate change.
Given the statement in
         your response that you face potential risks associated with the
physical effects of climate
         change--which may include more frequent or severe storms, typhoons,
flooding, rising sea
         levels and shortages of water, any of which could have a material
adverse effect on our
         business, financial condition, results of operations and cash
flows--please tell us how you
         determined that additional risk factor disclosure specifically
regarding climate change is
         not warranted at this time.
4.       In response to prior comment 4 you state that you assessed the current
effects of climate
         change regulation on your business, credit risks, technological
changes and market trends
         caused by climate change and deemed them immaterial. Provide us with
additional
         information supporting this assertion as your response appears to be
conclusory without
         adequately detailing various transition risks related to climate
change and the effect they
         may have on you. In addition, please tell us more about your
assessment of transition
         risks in connection with future legislation or regulation related to
climate change and
         explain how you considered providing disclosure regarding their
potential effects.

5.       Refer to prior comment 5. You state that the purchase and sale of
carbon credits or offsets
         have not been material to you and have not had a material effect on
your business,
         financial condition, results of operations and cash flows. Please
provide us with
         additional detail to support this statement, including quantitative
information.
 Randy Hyzak
LAS VEGAS SANDS CORP
October 26, 2021
Page 3

      You may contact Maryse Mills-Apenteng at 202-551-3457 or Pam Long at
202-551-
3765 with any questions.



FirstName LastNameRandy Hyzak                         Sincerely,
Comapany NameLAS VEGAS SANDS CORP
                                                      Division of Corporation
Finance
October 26, 2021 Page 3                               Office of Real Estate &
Construction
FirstName LastName