TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo July 16, 2020 Corey Sanders Chief Financial Officer MGM Resorts International 3600 Las Vegas Boulevard South Las Vegas, NV 89109 Re: MGM Resorts International Form 10-K for the year ended December 31, 2019 Filed February 27, 2020 File No. 001-10362 Dear Mr. Sanders: We have reviewed your filing 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 applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the year ended December 31, 2019 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Measures , page 40 1. We understand that you use Adjusted EBITDAR as a valuation measure. Please tell us why you believe it is appropriate to present this measure on a comparable basis. 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. Corey Sanders MGM Resorts International July 16, 2020 Page 2 You may contact Jeffrey Lewis, Staff Accountant, at (202) 551-6216 or Shannon Menjivar, Accounting Branch Chief, at (202) 551-3856 with any questions. FirstName LastNameCorey Sanders Sincerely, Comapany NameMGM Resorts International Division of Corporation Finance July 16, 2020 Page 2 Office of Real Estate & Construction FirstName LastName