December 7, 2018
Lyn Shenk
Branch Chief
Office of Transportation and Leisure
Division of Corporate Finance
U.S Securities & Exchange Commission
100 F Street, NE
Washington, D.C. 20549
| RE: | Churchill Downs Incorporated |
| Form 10-Q for Fiscal Quarter Ended September 30, 2018 |
| Filed October 31, 2018 |
| File No. 001-33998 |
Dear Mr. Shenk:
We are in receipt of the letter, dated November 28, 2018 (the “Comment Letter”), from the staff of the United States Securities and Exchange Commission (the “Staff”) with respect to the above-referenced filing by Churchill Downs Incorporated (the “Company”). The Staff requested that the Company respond to the Comment Letter within ten business days of November 28, 2018, or to advise the Staff when the Company would provide a response.
The Company advises the Commission that it is in the process of preparing a response and, as discussed, respectfully requests an extension until January 11, 2019.
Thank you for your consideration of the requested extension. If you have any questions or comments, please do not hesitate to contact the undersigned at (502) 636-4837.
| Sincerely, |
| /s/ Marcia A. Dall |
| Marcia A. Dall |
| Chief Financial Officer |
| cc: | Theresa Brillant, Securities and Exchange Commission |
| Brad Blackwell, Esq., Churchill Downs Incorporated |
| Chad Dobson, Churchill Downs Incorporated |
| Brian Fahrney, Esq., Sidley Austin LLP |
| Mark Rexroat, PricewaterhouseCoopers LLP |
600 N. HURSTBOURNE PKWY, SUITE 400 ● LOUISVILLE, KY, 40222 ● (502) 636-4400 ● www.churchilldownsincorporated.com