October 24, 2019
Doug Jones
Division of Corporation Finance
U.S. Securities & Exchange Commission
100 F Street, NE
Washington, D.C. 20549
| RE: | Churchill Downs Incorporated |
Form 8-K Furnished March 5, 2019
File No. 001-33998
Dear Mr. Jones:
We are in receipt of the letter, dated October 17, 2019 (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 receiving the Comment Letter, or to advise the Staff when the Company would provide a response.
The Company advises the Staff that it is in the process of preparing a response and, as discussed with the Staff, respectfully requests an extension until November 14, 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: | Stephen Kim, Securities and Exchange Commission |
Marcia Dall, Churchill Downs Incorporated
Chad Dobson, Churchill Downs Incorporated
Brian Fahrney, Sidley Austin LLP
Brian Lane, Gibson, Dunn & Crutcher LLP
Mark Rexroat, PricewaterhouseCoopers LLP
600 N. HURSTBOURNE PKWY, SUITE 400 • LOUISVILLE, KY, 40222• (502) 636-4400 • www.churchilldownsincorporated.com