Mail stop 03-05

      June 17, 2005

Via Fax & U.S. Mail

Mr. Daniel R. Lee
Chairman and Chief Executive Officer
Pinnacle Entertainment, Inc.
3800 Howard Hughes Parkway
Las Vegas, NV 89109

Re:	Pinnacle Entertainment, Inc. (the "Company")
      Form 10-K for the year ended December 31, 2004
      File No. 1-13641
	Filed March 16, 2005

Dear Mr. Lee:

      We have reviewed your response letter dated May 24, 2005 and
have the following comments.  Where indicated, we think you should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

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

Note 8 - Lease Obligations, page 72
1. It is our understanding based on our conversation with you on
June
15, 2005 that management, in conjunction with Deloitte, expects to
under take a review of company accounting policies with respect to
allocation of lease expense during a construction period.  Please
provide a summary of your new accounting policy and when you
anticipate implementation of the new policy.  It is our
understanding
that your properties in Missouri would be impacted by the
implementation of a new policy.
2. Please quantify the income statement impact to future periods
if
you had capitalized lease expense for L`Auberge.  In this regard,
we
would anticipate a difference in future periods for amounts
treated
as depreciation expense rather than lease expense.  As part of
your
analysis, also provide your assessment of when possession and
control
effectively passed to you for the L`Auberge property.  We have
read
your Ground Lease Agreement related to L`Auberge and it would
appear
that control passed to you early in the project due to the
following
factors:
* The lease was with the state of Louisiana;
* the lease agreement states that you (the tenant) have "obtained
all
licenses, permits and approvals form the Louisiana Riverboat
Gaming
Commission" and other applicable state regulators necessary to
operate a casino on such property;
* and the state of Louisiana had a vested interest in ensuring the
success of the project due to the creation of employment
opportunities in the state.
For guidance in preparing your analysis, refer to EITF 01-8.
3. In future filings, please provide disclosure of events that
could
cause you to surrender the L`Auberge property to the lessor under
the
terms stipulated in the Ground Lease Agreement.  As applicable,
you
should provide any necessary disclosures for any other properties
you
have under similar development arrangements.  Provide your
intended
disclosure.

* * * * *

      Please file your response to our comments via EDGAR within
10
business days from the date of this letter.  Please understand
that
we may have additional comments after reviewing your response.
You
may contact Tracie Northan at 202-551-3311 or me at 202-551-3812
if
you have any questions on our comments.


      Sincerely,



      Michael Fay
      Branch Chief Accountant

Via facsimile:  Stephen H. Capp, CFO
		(702) 784-7778