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                              January 29, 2024

       Jason K. Park
       Chief Financial Officer
       DraftKings Inc.
       222 Berkeley Street, 5th Floor
       Boston, MA 02116

                                                        Re: DraftKings Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2022
                                                            Response dated
January 8, 2024
                                                            File No. 001-41379

       Dear Jason K. Park:

              We have reviewed your January 8, 2024 response to our comment
letter and have the
       following comment(s).

              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. Unless
       we note otherwise, any references to prior comments are to comments in
our December 7, 2023
       letter.

       Response dated January 8, 2024

       General

   1.                                                   We note your response
to prior comment 1, particularly your view that information about
                                                        the Marketplace would,
at this point and for the foreseeable future, not be material to
                                                        investors in your
securities. You supported this view with quantitative information, but
                                                        did not address
materiality in qualitative terms. Please tell us why you believe the
                                                        information about the
Marketplace is not qualitatively material. In addition, for Collectible
                                                        NFTs, please tell us
the breakdown of the percentage of Collectible NFTs created by you
                                                        and separately by the
third parties. Additionally, please tell us the names of the third
                                                        parties that are linked
to the Third-Party Collectible NFTs, and tell us which services,
                                                        minting and/or custody
services, you provide to each such third-party and the estimated
                                                        value of payments that
you receive in connection with providing such services.
 Jason K. Park
DraftKings Inc.
January 29, 2024
Page 2
      With respect to the Reignmakers NFTs, which we note make up approximately
99% of
      your Marketplace NFTs for the year ended December 31, 2023, please state
whether such
      NFTs were minted by you, while you were a validator for Polygon. If you
did not mint
      such NFTs, please identify the party that minted them. In that light, we
note your
      statements that    [m]inting an NFT on the Polygon blockchain serves as a
certificate of
      authenticity    and that Polygon is an    unaffiliated commercial
counter-party of the
      Company.    To the extent there are or were conflicts of interest between
you and Polygon,
      please state as much, including any previous relationship you had as a
validator for
      Polygon and any payment, fees, or incentives that you received from
Polygon.

      Finally, with respect to Primary Sales by the Company, please explain in
further detail
      how you price Collectible NFTs and Reignmakers NFTs, both individually
and in digital
      pack of multiple NFTs. For secondary sales, please explain how you set
the de minimis
      price floor. Explain in further detail the revenue you earn on Secondary
Sales and Third-
      Party Collectible NFT Primary Sales.
2.    We note your response to prior comment 2. While we do not have any
further comments
      at this time regarding your responses, please confirm your understanding
that our decision
      not to issue additional comments should not be interpreted to mean that
we either agree or
      disagree with your responses, including any conclusions you have made,
positions you
      have taken and practices you have engaged in or may engage in with
respect to this
      matter, including in regards to any NFTs or other crypto assets that you
may develop or
      mint in the future or that you may support or facilitate the minting or
trading of in the
      future.
       Please contact Keira Nakada at 202-551-3659 or Suying Li at 202-551-3335
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Cara Wirth at 202-551-7127 or Dietrich King at 202-551-8071 with any other
questions.



                                                           Sincerely,
FirstName LastNameJason K. Park
                                                           Division of
Corporation Finance
Comapany NameDraftKings Inc.
                                                           Office of Trade &
Services
January 29, 2024 Page 2
cc:       Scott D Miller
FirstName LastName