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                            March 23, 2023

       Randy Hyzak
       Executive Vice President and Chief Financial Officer
       Las Vegas Sands Corp.
       5500 Haven Street
       Las Vegas, NV 89119

                                                        Re: Las Vegas Sands 
Corp.
                                                            Form 10-K for the 
year ended December 31, 2022
                                                            Filed February 3, 
2023
                                                            Form 8-K filed 
January 25, 2023
                                                            File No. 001-32373

       Dear Randy Hyzak:

              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-K for the year ended December 31, 2022

       Notes to Consolidated Financial Statements
       Note 7 - Property and Equipment, Net, page 96

   1.                                                   You disclose that the 
VML subconcessions agreement expired on December 31, 2022 and
                                                        that the Gaming Assets 
reverted to, and are now owned by the Macao government. You
                                                        further disclose that 
effective January 1, 2023, the Gaming Assets were temporarily
                                                        transferred to VML for 
the duration of the Concession in return for annual payments.
                                                        Please tell us how you 
accounted for transfer of the assets to the Macao Government on
                                                        December 31, 2022 and 
the subsequent temporary transfer back to VML for annual
                                                        payments. Within your 
response, please reference the authoritative accounting literature
                                                        management relied upon.
       Form 8-K filed January 25, 2023
 Randy Hyzak
Las Vegas Sands Corp.
March 23, 2023
Page 2
Exhibit 99.1
Non-GAAP measures, page 6

2.       We note your adjustments for hold-normalized casino revenue and 
expense to arrive at
         consolidated hold-normalized adjusted property EBITDA, hold-normalized 
adjusted
         property EBITDA for Macao Operations and Marina Bay Sands, and 
hold-normalized
         adjusted net loss from continuing operations attributable to LVS. 
Please tell us how you
         considered the guidance Question 100.04 of the Compliance & Disclosure 
Interpretations
         on Non-GAAP Financial Measures in your determination to present these 
measures.
       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 Howard Efron, Staff Accountant, at 202-551-3439 or 
Jennifer Monick,
Assistant Chief Accountant, at 202-551-3295 with any questions.



FirstName LastNameRandy Hyzak                                Sincerely,
Comapany NameLas Vegas Sands Corp.
                                                             Division of 
Corporation Finance
March 23, 2023 Page 2                                        Office of Real 
Estate & Construction
FirstName LastName