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                             May 30, 2024

       Marcus Glover
       Chief Financial Officer
       Bally's Corporation
       100 Westminster Street
       Providence, RI 02903

                                                        Re: Bally's Corporation
                                                            Form 10-K for the
year ended December 31, 2023
                                                            File No. 001-38850

       Dear Marcus Glover:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-K for the year ended December 31, 2023

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Results of Operations, page 43

   1.                                                   We note you have
identified multiple factors that impact your operating results but it does
                                                        not appear that you
have separately quantified each factor. For example purposes only,
                                                        you state that gaming
revenue increased due to organic growth, recent acquisitions and a
                                                        newly opened temporary
casino. When there are multiple factors impacting your operating
                                                        results, please revise
your disclosures to separately quantify the impact from each factor.

       Notes to Consolidated Financial Statements
       10. Goodwill and Intangible Assets, page 87

   2.                                                   We note your disclosure
of certain items that are valued on a recurring and non-recurring
                                                        basis that have
utilized level 3 inputs. We note you have provided quantitative information
                                                        about the significant
unobservable inputs for Sinclair Performance Warrants, however, it
                                                        does not appear that
you have provided such quantitative information for other items (e.g.,
 Marcus Glover
Bally's Corporation
May 30, 2024
Page 2
         a trademark within the International Interactive segment resulting in
impairment in 2023,
         contingent consideration) that you have identified as utilizing level
3 inputs. Please tell us
         how you determined it was unnecessary to disclose quantitative
information about the
         significant unobservable inputs for such items in accordance with ASC
820-10-50-2(bbb).
3.       Please clarify for us the level of the fair value hierarchy within
which the fair value
         measurements are categorized in their entirety (Level 1, 2, or 3) for
the three gaming
         licenses within the Casinos & Resorts segment that resulted in
impairment during 2023
         and the indefinite lived trademark within the International
Interactive segment that
         resulted in impairment in 2022. Please tell us how you complied with
ASC 820-10-50-
         2(b) or tell us how you determined the disclosure of the level is not
necessary. To the
         extent such items were valued using level 3 inputs, please tell us how
you determined it
         was unnecessary to disclose quantitative information about the
significant unobservable
         inputs for such items in accordance with ASC 820-10-50-2(bbb).
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       Please contact Howard Efron at 202-551-3439 or Jennifer Monick at
202-551-3295 with
any questions.



FirstName LastNameMarcus Glover                                 Sincerely,
Comapany NameBally's Corporation
                                                                Division of
Corporation Finance
May 30, 2024 Page 2                                             Office of Real
Estate & Construction
FirstName LastName