United States securities and exchange commission logo




                                                                                
                            July 3, 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 reviewed your April 6, 2023 response to our comment 
letter and have the
       following comment. In our comment, we may ask you to provide us with 
information so we may
       better understand your disclosure.

              Please respond to our comment 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
       comment applies to your facts and circumstances, please tell us why in 
your response.

             After reviewing your response to our comment, we may have 
additional
       comments. Unless we note otherwise, our references to prior comments are 
to comments in our
       March 23, 2023 letter.

       Form 10-K for the year ending December 31, 2022

       Form 8-K filed January 25, 2023
       Exhibit 99.1
       Non-GAAP Measures, page 6

   1.                                                   We note your response 
to comment 2. We believe 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 are inconsistent 
with Question 100.04 of the Non-GAAP Financial Measures
                                                        Compliance and 
Disclosure Interpretations. Please revise to remove the non-GAAP
                                                        measures that include 
adjustments for hold-normalized casino revenue and expense.
 Randy Hyzak
Las Vegas Sands Corp.
July 3, 2023
Page 2

       You may contact Howard Efron at 202-551-3439 or Jennifer Monick at 
202-551-3295 if
you have questions regarding comments on the financial statements and related 
matters.



FirstName LastNameRandy Hyzak                          Sincerely,
Comapany NameLas Vegas Sands Corp.
                                                       Division of Corporation 
Finance
July 3, 2023 Page 2                                    Office of Real Estate & 
Construction
FirstName LastName