<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
United States securities and exchange commission logo





                            October 14, 2021

       Blake Sartini
       Chairman of the Board and Chief Executive Officer
       Golden Entertainment, Inc.
       6595 S Jones Boulevard
       Las Vegas, NV 89118

                                                        Re: Golden
Entertainment, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Filed March 12,
2021
                                                            File No. 000-24993

       Dear Mr. Sartini:

              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 the Fiscal Year Ended December 31, 2020

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 28

   1.                                                   Please disclose the
business reasons for the changes between periods in each segment's
                                                        operating expenses and
ASC 280 segment profit (discussed in Note 15 of your financial
                                                        statements), as well as
the amounts shown in the Corporate and Other column. In
                                                        circumstances where
there is more than one business reason for a material change between
                                                        periods, please
quantify the incremental impact of each individual business reason
                                                        discussed on the
overall change in the line item. Refer to Item 303(b) of Regulation S-K.
 Blake Sartini
FirstName  LastNameBlake
Golden Entertainment, Inc. Sartini
Comapany
October 14,NameGolden
            2021        Entertainment, Inc.
October
Page 2 14, 2021 Page 2
FirstName LastName
Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 2 - Summary of Significant Accounting Policies
Revenue Recognition, page 51

2.       Please tell us in detail how you determined the participation
agreements are not subject to
         ASC 842 and that ASC 606 applies instead. For the participation
agreements, also
         provide us with your assessment of why you control the
revenue-producing
         arrangement, rather than the business location holding the applicable
gaming
         license, along with your analysis of the principal versus agent
considerations in
         paragraphs 38-40 of ASC 606-10-55.
3.       For wagering contracts that include complimentary products and
services and/or a loyalty
         program, please tell us why you do not allocate the transaction price
between these
         incentives and gaming revenues on a proportionate basis. Refer to ASC
606-10-32-31.
Note 15 - Segment Information, page 74

4.       Please tell us and disclose the factors used in determining your
reportable segments,
         including whether operating segments have been aggregated. Refer to
ASC 280-10-50-
         21. If you are aggregating operating segments, please also tell us in
detail the analysis
         you performed in determining the criteria in ASC 280-10-50-11 were
met. If you are not
         aggregating operating segments, please explain in detail how the
lower-level operating
         results discussed on your earnings calls (STRAT casino, Las Vegas
locals casinos,
         Laughlin casinos, Pahrump casinos, Rocky Gap casino, Nevada
distributed gaming and
         Montana distributed gaming) and in your Item 2.02 Forms 8-K (Nevada
casinos,
         Maryland casino, Nevada distributed gaming and Montana distributed
gaming) are not
         indicative of your operating segments being at a lower level than your
reportable
         segments. Also, refer to ASC 924-280-50-1.
5.       Please tell us your basis for presenting two measures of each segment
 s profit (net income
         and adjusted EBITDA) in the ASC 280 segment footnote. Also, explain
why adjusted
         EBITDA is permitted to be disclosed in the ASC 280 segment footnote,
when the net
         income measure appears to be most consistent with GAAP. Refer to ASC
280-10-50-
         27 and 50-28.
 Blake Sartini
Golden Entertainment, Inc.
October 14, 2021
Page 3

        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 Keira Nakada at 202-551-3659 or Rufus Decker at
202-551-3769
with any questions.



FirstName LastNameBlake Sartini                           Sincerely,
Comapany NameGolden Entertainment, Inc.
                                                          Division of
Corporation Finance
October 14, 2021 Page 3                                   Office of Trade &
Services
FirstName LastName
</TEXT>
</DOCUMENT>
