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                             December 21, 2023

       Peter Jackson
       Chief Executive Officer
       Flutter Entertainment plc
       Belfield Office Park, Beech Hill Road
       Clonskeagh, Dublin 4, D04 V972
       Ireland

                                                        Re: Flutter
Entertainment plc
                                                            Amendment No. 1 to
Draft Registration Statement on Form 20-F
                                                            Submitted December
6, 2023
                                                            CIK No. 0001635327

       Dear Peter Jackson:

            We have reviewed your amended draft registration statement and have
the following
       comments.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

               After reviewing the information you provide in response to this
letter and your amended
       draft registration statement or filed registration statement, we may
have additional
       comments. Unless we note otherwise, any references to prior comments are
to comments in our
       November 16, 2023 letter.

       Amendment No. 1 to Draft Registration Statement on Form 20-F

       Business Overview, page 57

   1.                                                   We note your response
to prior comment 6. Please revise to clarify whether any aspects of
                                                        your Positive Impact
Plan are required to be implemented by management, or if there are
                                                        any specific milestones
or actions that must be taken in order to achieve the stated
                                                        goals. If not, please
revise to clearly state as such.
       Item 5. Operating and Financial Review and Prospects
       Key Operational Metrics, page 84

   2.                                                   Your revised disclosure
in response to prior comment 4 states that multi-product players
 Peter Jackson
FirstName  LastNamePeter
Flutter Entertainment plc Jackson
Comapany21,
December    NameFlutter
               2023      Entertainment plc
December
Page  2    21, 2023 Page 2
FirstName LastName
         that use a single brand are not duplicated when determining total AMPs
in each division
         or the Group's total AMPs, and players that use multiple brands within
a division would
         be counted as an AMP for each brand that they use. Please revise to
address the following:
             Identify the significant brands that cross multiple product
categories and the related
              product categories for each significant brand.
             Explain why you utilize a different methodology to count players
that use multiple
              brands within a division and not multi-product players that use a
single brand,
              specifically clarifying the significance of brands in determining
AMPs.
             Explain why duplicate counting of players that use multiple brands
within a division
              does not result in a difference between the aggregate of AMPs by
geographic division
              and total Group AMPs.
             In your response, provide us with examples of how players can be
counted in your
              AMPs measure based on product, brand and division to add context
to your definition
              of AMPs on page 58.
3.       We note your response to prior comment 10. Please address the
following regarding
         AMPs:
             Revise to discuss the extent to which you use AMPs in managing
your business,
            across product categories, geographic divisions, and at the Group
level.
             Explain what is meant by the reference in your response to
"quantum" playing
            individual products.
             Revise to quantify total Group AMPs for the prior comparable
periods. In this regard
            we note that you quantify the increases in AMPs as part of your
discussion and
            analysis of consolidated results on pages 90 and 91.
             In your response, provide us with the breakdown of AMPs between
sportsbooks and
            iGaming players by segment for each period presented, if available.
             Further explain to us why you believe providing such breakdown of
AMPs would not
            be meaningful for an understanding of your business. In this regard
we note
            discussion and quantification of the increase in AMPs in relation
to iGaming
            revenues for the U.S. geographic division on page 93.
4.       Regarding your response to prior comment 10 as it relates to iGaming
products, please
         explain why the lack of variability of outcome causes staking
information for iGaming to
         be a less relevant metric. In your response, provide us with
quantified information
         of stakes or a similar metric for your iGaming products by geographic
segment for each
         period presented, to the extent available. In addition, tell us the
net revenue margin or
         similar measure for iGaming by geographic segment for each period
presented, if
         available.
Trends and Factors Affecting Our Future Performance, page 85

5.       We note your revised disclosure in response to prior comment 3 that
remediation actions
         related your internal control over financial reporting are expected to
be time-consuming
         and put significant demands on the company's financial and operational
resources. While
         you state that you cannot provide an estimate of the costs expected to
be incurred, please
 Peter Jackson
Flutter Entertainment plc
December 21, 2023
Page 3
       revise here to discuss, in qualitative terms, the impact of remediation
if the related costs
       are reasonably likely to be material. Refer to Item 5.D of Form 20-F.
General

6.     We note your release of your third quarter trading update on your
company website,
       please include a discussion of your financial performance for this
period in your
       registration statement.
       Please contact Joyce Sweeney at 202-551-3449 or Kathleen Collins at
202-551-3499 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Austin Pattan at 202-551-6756 or Matthew Derby at 202-551-3334 with any
other
questions.



                                                              Sincerely,
FirstName LastNamePeter Jackson
                                                              Division of
Corporation Finance
Comapany NameFlutter Entertainment plc
                                                              Office of
Technology
December 21, 2023 Page 3
cc:       Joshua Bonnie
FirstName LastName