August 17, 2005

Mail Stop 3561

Via US Mail and Facsimile

Ms. Kimberly Tharp
Chief Financial Officer
3500 N.W. 37th Avenue
Miami, Florida 33142

Re:	Florida Gaming Corporation
	Form 10-KSB for the year ended December 31, 2004
	Forms 10-QSB for the periods ended March 31, 2005 and June
30,
2005
	Commission file #: 000-09099

Dear Ms. Tharp:

We have reviewed your August 15, 2005 response letter and have the
following comments.  Where expanded or revised disclosure is
requested, you may comply with these comments in future filings.
If
you disagree, we will consider your explanation as to why our
comments
are inapplicable or a revision is unnecessary.  We also ask you to
provide us with supplemental information so we may better
understand
your disclosure.  Please be as detailed as necessary in your
explanation.  We look forward to working with you in these
respects
and welcome any questions you may have about any aspects of our
review.


* * * * * * * * * * * * * * * * * * * * * * *


Form 10-KSB for the year ended December 31, 2004

Note L.  Real Estate Held for Sale, page 24

1. We note from your response to comment 3 that the amount of the
real
estate valuation reserve increased between 2003 and 2004, however
we
do not understand how there were no charges to expense during 2004
if
the reserve increased in amount.  Please show us and include in
future
filings, the changes to the valuation reserve during the year,
including the amounts charged to expense to increase the reserve
balance and any amounts written off to reduce the valuation
reserve
balance.



Form 10-QSB for the period ended June 30, 2005

- - Liquidity and Capital Resources, page 19

2. We note your disclosure that negative working capital increased
during 2005.  In this regard, please revise future filings to
disclose
the impact of this deficit on your ability to operate your
business
and meet your obligations as they come due.  Also, revise future
filings to disclose any reasonably possible outcomes related to
your
lack of liquidity, such as curtailment of operations or lack of
implementation of business plan.  See Item 303(b)(1) of Regulation
S-
B.

* * * * * * * * * * * * * * * * * * * * * * *

As appropriate, please file your response to these comments via
EDGAR
within 10 business days or tell us when you will provide us with a
response.  Please furnish a cover letter that keys your responses
to
our comments and provides any requested supplemental information.

You may contact Claire Erlanger at 202-551-3301 or Kathy Mathis at
202-551-3383 if you have questions.

								Sincerely,


								Linda Cvrkel
								Branch Chief
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Ms. Kimberly Tharp
Florida Gaming Corporation
August 17, 2005
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