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VIA EDGAR

September 22, 2022

Frank Knapp

Jennifer Monick

Division of Corporation Finance

Office of Real Estate & Construction

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re: MGM Resorts International

Form 10-K for the year ended December 31, 2021
Filed February 25, 2022

Form 8-K Filed August 3, 2022

File No. 001-10362

Dear Mr. Knapp and Ms. Monick:

Enclosed for filing with the Securities and Exchange Commission on behalf of MGM Resorts International (the “Company”) is the Company’s response to your letter dated September 19, 2022. The Commission’s letter set forth two specific comments (the “Comments”) on the Company’s Form 8-K filed August 3, 2022.

Set forth below are the Company’s responses to the Comments, which the Company has requested the undersigned submit to you on its behalf. For purposes of facilitating the Staff’s review of the Company’s responses to the Comments, the original comments are included at the beginning of the response.

Form 8-K filed August 3, 2022

Exhibit 99.1

Second Quarter 2022 Financial Highlights

Consolidated Results, page 2

41086.00000

1.We note your disclosure that adjusted EBITDAR information is a valuation metric and

should not be used as an operating metric. We further note your presentation of

Adjusted EBITDAR margin. Please tell us what consideration you gave to your inclusion of this margin resulting in Adjusted EBITDAR also being viewed a measure of your operating performance.

In future filings, the Company will revise its presentation to remove Adjusted EBITDAR margin.

Adjusted Diluted Earnings Per Share, page 3

2.We note your adjustment for loss (gain) related to equity investments to arrive at adjusted diluted earnings per share. Please tell us the nature of this adjustment and how it is derived.

Loss (gain) related to equity investments reflects the net unrealized loss (gain) relating to equity investments for which the Company has elected the fair value option of ASC 825 and equity investments accounted for under ASC 321 for which there is a readily determinable fair value.

If there are additional comments or questions, please do not hesitate to contact the undersigned at (212) 530-5022.

Very truly yours,

/s/ Rod Miller

_______________________

Rod Miller

Copies to:    William J. Hornbuckle

Jonathan S. Halkyard

John M. McManus

Todd Meinert

41086.00000