November 28, 2018

Marcia A. Dall
Executive Vice President and Chief Financial Officer
Churchill Downs Inc.
600 North Hurstbourne Parkway
Suite 400
Louisville, Kentucky 40222

       Re: Churchill Downs Inc.
           Form 10-Q for Fiscal Quarter Ended September 30, 2018
           Filed February 28, 2018
           File No. 001-33998

Dear Ms. Dall:

       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 Fiscal Quarter Ended September 30, 2018

15. Segment Information, page 20

1.    We note your presentation of disaggregated revenue by reportable segment
and by
      location on page 22. With respect to the disclosure requirements of ASC
606-10-50-5,
      please tell us how you considered the guidance in paragraphs ASC
606-10-55-89 through
      55-91 in selecting the appropriate categories to use to disaggregate
revenue. In this
      regard, we note from page 11 that the timing of transfer of goods or
services to customers
      occurs both at points in time and over time. We also note from your
investor presentation
      dated November 2, 2018 that, for The Kentucky Derby, ticketing is a
significant driver of
      revenues and multiyear sponsorship revenue supports long-term
profitability and stability
      of earnings.
 Marcia A. Dall
Churchill Downs Inc.
November 28, 2018
Page 2
2.       Please also tell us what consideration you gave to reporting revenues
from external
         customers for each product and service or each group of similar
products and services.
         Refer to ASC 280-10-50-40.
       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 Theresa Brillant at 202-551-3307 or Lyn Shenk at
202-551-3380 with
any questions.



FirstName LastNameMarcia A. Dall                             Sincerely,
Comapany NameChurchill Downs Inc.
                                                             Division of
Corporation Finance
November 28, 2018 Page 2                                     Office of
Transportation and Leisure
FirstName LastName