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                             August 24, 2023

       Felicia R. Hendrix
       Executive Vice President and Chief Financial Officer
       PENN Entertainment, Inc.
       825 Berkshire Blvd., Suite 200
       Wyomissing, Pennsylvania 19610

                                                        Re: PENN Entertainment,
Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2022
                                                            Filed February 23,
2023
                                                            File No. 000-24206

       Dear Felicia R. Hendrix:

              We have reviewed your filing and have the following comments. In
some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to these comments 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
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for Fiscal Year Ended December 31, 2022

       General

   1.                                                   We note that you
provided more expansive disclosure in your 2022 Corporate Social
                                                        Responsibility Report (
  CSR Report   ) than you provided in your SEC filings. Please
                                                        advise us what
consideration you gave to providing the same type of climate-related
                                                        disclosure in your SEC
filings as you provided in your CSR Report.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
       33

   2.                                                   To the extent material,
please discuss the indirect consequences of climate-related
                                                        regulation or business
trends, such as the following:

                                                              decreased demand
for products or services that produce significant greenhouse gas
                                                            emissions or are
related to carbon-based energy sources;
 Felicia R. Hendrix
PENN Entertainment, Inc.
August 24, 2023
Page 2
                increased demand for products or services that result in lower
emissions than
              competing products or services;
                increased competition to develop innovative new products that
result in lower
              emissions;
                increased demand for generation and transmission of energy from
alternative energy
              sources; and
                any anticipated reputational risks resulting from operations or
products that produce
              material greenhouse gas emissions.
3.       We note disclosure that your properties are at risk of experiencing
extreme weather
         conditions (such as snowstorms, tornadoes, and/or flooding) and that
your operations are
         subject to disruptions or reduced patronage as a result of severe
weather conditions and
         natural disasters. Please discuss the physical effects of climate
change on your operations
         and results. This disclosure may include the following:

                severity of weather, such as floods, hurricanes, sea levels,
arability of farmland,
              extreme fires, and water availability and quality;
                quantification of material weather-related damages to your
property or operations;
                potential for indirect weather-related impacts that have
affected or may affect your
              major customers or suppliers;
                decreased agricultural production capacity in areas affected by
drought or other
              weather-related changes; and
                the extent to which extreme weather events have reduced the
availability of insurance
              or increased the cost of insurance.

         Include quantitative information for each of the periods covered by
your Form 10-K and
         explain whether increased amounts are expected in future periods.
4.     Please provide disclosure about your purchase or sale of carbon credits
or offsets and any
       material effects on your business, financial condition, and results of
operations. Include
FirstName LastNameFelicia R. Hendrix
       quantitative information for each of the periods covered by your Form
10-K and for future
Comapany   NamePENN
       periods           Entertainment, Inc.
               in your response.
August 24, 2023 Page 2
FirstName LastName
 Felicia R. Hendrix
FirstName  LastNameFelicia
PENN Entertainment,   Inc. R. Hendrix
Comapany
August  24, NamePENN
            2023        Entertainment, Inc.
August
Page  3 24, 2023 Page 3
FirstName LastName
        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.

      Please contact Ronald (Ron) E. Alper at 202-551-3329 or Jennifer Angelini
at 202-551-
3047 with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Real Estate
& Construction