February 6, 2019 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 completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Transportation and Leisure