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                                                           October 22, 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 limited our review of your filing to the financial statements
and related
disclosures 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-Q for the Quarterly Period Ended June 30, 2018

Note 2. Revenue Recognition
Contracts with Customers with Multiple Promised Goods and Services, page 13

1.    You indicate that you use the residual method for software licenses when
observable
      prices are uncertain or highly variable. Please explain how you met one
of the criteria in
      ASC 606-10-32-34(c). For software licenses where you concluded the
pricing is highly
      variable provide a comprehensive, quantitative discussion of such
variability to support
      your conclusion. As part of your response, please quantify the amount of
revenue
      recognized for software licenses where the residual method is used.
 Michael Quartieri
Scientific Games Corporation
October 22, 2018
Page 2
Gaming Operations, page 13

2.       We note that gaming operations contracts may include leasing and other
services. Please
         describe for us, in greater detail, how these arrangements are
accounted for including any
         lease contracts. You should address whether you determined if any
lease contracts or
         components are within the scope of ASC 840, how such contracts are
separated from the
         rest of the arrangement, what the performance obligations are for the
components
         accounted for under ASC 606 and the basis for the timing of revenue
recognition for
         each. Refer to the authoritative guidance you relied upon.
3.       Please tell us and disclose, if material, the amount of rental income
revenue that is outside
         the scope of ASC 606. Refer to ASC 606-10-50-4(a).
Lottery Instant Products, page 14

4.       We note for CSP contracts you recognize revenue over time measured by
when a lottery
         retailer activates any associated instant tickets. Please tell us how
you determined that this
         is the appropriate measure of progress towards which you have
transferred control. Also,
         please explain why your accounting for CSP contracts differs from the
sale of instant
         products on a POS basis where revenue is recognized when the lotteries
have taken
         delivery of the shipments.
       In closing, 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.

       You may contact Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or
Christine
Dietz, Assistant Chief Accountant, at 202-551-3408 with any questions.



                                                                Sincerely,
FirstName LastNameMichael Quartieri
                                                                Division of
Corporation Finance
Comapany NameScientific Games Corporation
                                                                Office of
Information Technologies
October 22, 2018 Page 2                                         and Services
FirstName LastName
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