TEXT-EXTRACT 2 filename2.txt December 12, 2018 Michael Quartieri Chief Financial Officer Scientific Games Corporation 6601 Bermuda Road Las Vegas, Nevada 89119 Re: Scientific Games Corporation Form 10-K for the Fiscal Year Ended December 31, 2017 Filed March 1, 2018 Form 10-Q for the Quarterly Period Ended June 30, 2018 Filed August 2, 2018 File No. 001-11693 Dear Mr. Quartieri: We have reviewed your October 31, 2018 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment apply to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our October 22, 2018 letter. Form 10-Q for the Quarterly Period Ended June 30, 2018 Note 2. Revenue Recognition Lottery Instant Products, page 14 1. We note your response to prior comment 4. Please address the following: Help us better understand the nature of the services provided in your CSP arrangements. Describe the services in detail and further explain why you believe each day of service is distinct. In addition, describe how and to what extent you manage inventory levels at the retail outlets. Michael Quartieri Scientific Games Corporation December 12, 2018 Page 2 Please further explain what consideration you gave to whether the underlying services you have identified were separate performance obligations. Your response indicates that you recognize revenue over time based on ultimate ticket activation. Please clarify this statement as your reference to activation implies that you recognize revenue at a point in time. Please quantify the revenues recognized from CSP arrangements in 2018. You may contact Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Christine Dietz, Assistant Chief Accountant, at 202-551-3408 if you have questions. Sincerely, FirstName LastNameMichael Quartieri Division of Corporation Finance Comapany NameScientific Games Corporation Office of Information Technologies December 12, 2018 Page 2 and Services FirstName LastName