Greenberg Traurig, P.A.

1221 Brickell Avenue

Miami, Florida 33131

Michele Keusch

(305) 579-0827

September 27, 2006

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549-0404

Attention: Joe Foti

Registration Statement on Form SB-2

Filed August 4, 2006

File No. 333-136341

Ladies and Gentlemen:

On behalf of our client, Full House Resorts, Inc., a Nevada corporation (the “Company” or “we”), transmitted herewith are the Company’s responses to the Staff’s comments to the Registration Statement on Form SB-2 filed on August 4, 2006 (the “SB-2”), which comments were set forth in a letter dated August 29, 2006 (the “Comment Letter”) to Andre M. Hilliou, Chief Executive Officer and Director of the Company. For ease of reference, we have reproduced comments set forth in the Comment Letter, as numbered, before each response below.

Risk Factors — Assessing Internal Controls over Financial Reporting, page 11

RESPONSE: The Company has added language to the risk factor on page 11 discussing the proposed change.

Securities and Exchange Commission

Attention: Joe Foti

Page 2

Risk Related to our Common Stock

Our controlling stockholder has significant influence over management and has the power to elect a majority of our board, page 12

RESPONSE: Paragraph 2 of SFAS No. 57 to require disclosure of any “material related party transactions, other than compensation arrangements, expenses allowances, and other similar items in the ordinary course of business.” The Company does not believe that mere ownership of a controlling interest is a transaction contemplated by this requirement. Accordingly, no additional disclosure has been made in the amendment in response to this comment. When and if the Company enters into any transactions with related parties, these are disclosed in the footnotes to the financial statements pursuant to SFAS No. 57.

Management Discussion and Analysis or Plan of Operation

Results of Operations, page 29

RESPONSE: A discussion of the results of operations for Stockman’s has been added on pages 36 - 38.

Securities and Exchange Commission

Attention: Joe Foti

Page 3

Critical Accounting Estimates and Policies

Summary of long-term assets related to Indian casino projects, page 27

RESPONSE: As requested, the Company has expanded the table summarizing long-term assets related to Indian casino projects to include the components of the long-term assets by project on page 28. Please note that the Michigan project is the only individually significant project and, as a result, the others have been combined for presentation purposes.

RESPONSE: The discussion of the agreement with the Michigan tribe, the only individually significant Indian project, has been expanded on page 28.

The current status and the timing of such developments in relation to the conditions listed on page 28 are included in the “critical accounting estimates and policies” section of the MD&A in the narrative for the Michigan project, the only individually significant project. The Company has also added the current status of construction financing for the Michigan project as requested and clarified the timing of certain other developments. As a result, management believes that this added information addresses the informational concern marked by your comment. In addition, since the conditions largely affect timing and not probability of opening, as explained further below, a probability factor is not a material assumption in the valuation model. Before entering into an arrangement with an

Securities and Exchange Commission

Attention: Joe Foti

Page 4

Indian tribe, management performs a thorough financial and legal analysis and is therefore comfortable concluding that the project will likely be completed as planned. However, the exact timing of completion is substantially less certain primarily because of anticipated legal, weather-related and other construction delays. Accordingly, management believes that the status of the conditions listed on page 28 primarily and typically affect the timing of completion, rather than its probability. As a result, the probability of project completion and miscellaneous industry and project specific risks are primarily considered in the selection of an appropriate discount rate as more fully described on page 29. On the other hand, the expected timing of construction and resulting commencement of operations has a significant and separately identifiable effect on the valuation model. Accordingly, the sensitivity of these most significant assumptions, the expected opening date and the discount rate, is demonstrated on page 29.

RESPONSE: Additional disclosure regarding how the Company determined the “estimated years until opening of the casino” for the Michigan project, the only individually significant project at this time, has been added on page 28.

The fair value notes receivable model considers expected future interest rates prior to and during operation of the casino. As indicated on page 29, the Company believes that the stated interest rates of the receivables during the loan repayment term, if not repaid prior to commencement of operations, is commensurate with the expected inherent risk at such time based upon commercially available rates for similar credit and disclosure of such rate for the projects has been added. Prior to commencement of operations of the casino, the expected future interest rate impacts the calculation and selection of an appropriate discount rate using the Capital Asset Pricing Model. As explained on page 29, rates of return and adjustments thereto are objectively supportable

Securities and Exchange Commission

Attention: Joe Foti

Page 5

because they are based upon published investment return benchmarks, size and industry beta adjustment factors. These factors are also applied considering project specific conditions using the Capital Asset Pricing Model. As additionally stated, gaming industry return rates typically used by appraisers and investors were also considered.

The aggregate advancement amounts are disclosed on page 29 as the “aggregate advances/face amount of the notes receivable.” There have been no repayments. The repayment term for the Michigan note has been added as indicated in the response to comment 5. As previously indicated, in the valuation model, most changes in the status of the conditions listed on page 28, affect only the timing estimate and therefore the probability estimate typically does not have a material impact on the valuation model and resultant value estimate. However, as discussed in more detail in the response to comment 5 above, the status of the conditions mentioned do materially impact the Company’s timing estimate which is a material assumption in the valuation model. Accordingly, additional detail has been added to explain the determination of “estimated years until opening the casino.” The sensitivity of the most significant valuation assumptions, the expected opening date and the discount rate, is demonstrated on page 29.

Please also describe the specific basis upon which management concluded each of the above assumptions were appropriate, given your historical operating experience, local casino market conditions, and current political environment. Also describe in reasonable detail the sensitivity of these assumptions to your reported operating results.

RESPONSE: Additional disclosure regarding the assumptions management uses to assess impairment has been added on page 27.

Securities and Exchange Commission

Attention: Joe Foti

Page 6

Liquidity and Capital Resources, page 31.

RESPONSE: Additional disclosure regarding funding of construction has been added on page 33.

RESPONSE: Additional disclosure regarding the estimate and source of these costs has been added on page 33.

Index to Consolidated Financial Statements

Audited Financial Statements of Full House Resort, Inc.

Consolidated Statements of Income, page F-4 and F-17

Securities and Exchange Commission

Attention: Joe Foti

Page 7

RESPONSE: The pro forma financial statements have been revised to separately state the adjustment for the dividend instead of showing estimated proceeds net of the dividend and to include the additional shares of common stock from the conversion of the preferred in the pro forma weighted average number of shares. See pages F-33 through F-37.

The Company’s understanding of SAB Topic 1-B(3) is that it applies only to post balance sheet declarations of dividends that have actually occurred and only to such dividends declared by a subsidiary. The cumulative preferred stock dividends, which have been undeclared, will be declared and paid in the foreseeable future only out of available proceeds and only if and when the offering goes effective as planned. Accordingly, since the effect of the dividend is set forth in the accompanying separate pro forma financial information presented pursuant to Item 310(d) of Reg. S-X, the Company believes including such pro forma information in the historical financial statements may give the misleading impression that the dividend is more likely to occur than the other transactions included in the pro forma information. As a result, no changes have been made in the annual or interim historical consolidated financial statements presented in the amendment for this matter.

RESPONSE: While the Company does not concur with the Staff’s characterization of “Income from operations before unrealized gains on notes receivable and arbitration award, net” as a “non-GAAP caption,” and believes the subtotal is helpful to make the financial statements easier to understand, the requested caption and subtotal amounts have been deleted.

Securities and Exchange Commission

Attention: Joe Foti

Page 8

RESPONSE: The Company’s principal business activities entail substantial cost expenditures on behalf of Indian tribes in the development of gaming projects. In connection with a project in California, in August 2001, the Company received notice from the Torrez-Martinez Tribe of its intent to breach the contract and sever its relationship with the Company. The Company determined that it had incurred costs totaling over $1 million on behalf of the tribe which had been expensed based on the Company’s accounting policies at the time. In 2004, after many failed attempts at negotiating to re-establish its relationship with the tribe, the Company commenced an arbitration proceeding. In February 2005, the Company received notice from the American Arbitration Association of an award against the Tribe and on December 21, 2005, the Company succeeded in reaching a settlement amounting to a net recovery of $922,611.

There is almost no broadly applicable guidance to be found at any level of the GAAP hierarchy, authoritative or not, as to the classification of income or expense items within or outside of operating income in a two-step (or multi-step) income statement or statement of operations. Paragraph 26 of APB Opinion No. 30 requires separate presentation on a single line (or alternatively in the notes) of charges or credits that are the financial effects of any material event or transaction that is unusual or infrequent (but not both) but does not speak of its operating or non-operating character or classification. Accordingly, issuers and their auditors usually must apply considerable judgment as to the placement of such material charges or credits. Such judgment is required even to interpret or apply the guidance implied by line item 7 of Rule 5-03 of Reg. S-X, which would appear to require “amounts earned from (a) dividends, (b) interest on securities, (c) profits on securities (net of losses), and (d) miscellaneous other income” to be excluded from operating income or any of its components.

The language in Rule 5-03 appears to imply that non-operating income (and expense) should describe primarily credits and charges relating to financing and investment activities, rather than operating activities, such as those terms are used and described in SFAS No. 95 with regard to the statement of cash flows. No definition or guidance was found as to what is meant in Rule 5-03 by “miscellaneous other income.” The term does not appear to relate to the frequency of occurrence of the credits or charges, as discussed in APB 30, but rather its relationship to the issuer’s normal business operating activities ordinarily should be the dispositive consideration. This principle is applied in limited respect to “restructuring” charges as discussed in SFAS No. 146 in SAB Topic 5P3, which effectively states that in a classified or “two-step” income statement format (i.e., one that presents operating revenues, expenses, and income followed by other income and expense items), an entity must classify as a component of operating income rather than non-operating (or “other”) expense a restructuring charge that relates to assets or activities for which the associated revenues and expenses historically have been included in operating income.

Securities and Exchange Commission

Attention: Joe Foti

Page 9

In the absence of other applicable literature that states to the contrary, the Company believes there is no persuasive reason that the same principle should not be more broadly applied, such as to charges and credits resulting from the resolution of disputes such as through litigation arbitration or settlement. One should look to the nature of the dispute and where the debits and credits have or would have ordinarily gone, had the damages being recovered never been incurred.

In the Company’s case, since the matter involved the Company’s normal operational activities, the damages represented, and were recorded as, operating expenses and the recovery, had it occurred in the normal course of business would have been recorded as operating revenues over time. Therefore, it makes sense that the recovery of the Company’s expenses through settlement also be reflected as operations.

Note 4 – Investment in Unconsolidated Joint Ventures, page F-11 and F-17

RESPONSE: As the Company understands it, Item 310(b)(2)(iii) of Regulation S-B does not require presentation of income from operations for equity investees, but rather it requires presentation of “Sales, gross profit, net income (loss) from continuing operations and net income” [emphasis added]. Since GED has no discontinued operations, net income is income from continuing operations, which need not and is not presented separately. In fact, in this case, net income is also income from operations.

Note 5 – Notes Receivable, Tribal Governments, page F-11

RESPONSE: A notes-receivable roll-forward schedule has been added on pages F-13 and F-22.

Securities and Exchange Commission

Attention: Joe Foti

Page 10

Note 6 – Contract Rights, page F-l2

RESPONSE: The disclosure in Footnote 6 has been revised on page F-14. Effectively two types of rights were acquired from a third party, management contract rights (the remaining 50%) plus the right to control the development processes, each limited life intangible asset representing a defined revenue stream under a service contract which should be capitalized and amortized under SFAS No. 142, paragraphs 9 and 12 (as opposed to internally incurred costs of development activities, which are expensed). Management believes that there was no objective basis for segregating the cost between the two types of rights nor was there any practical reason to do so. But had the cost been so segregated, amortization of the portion assigned to the management contract rights would not have commenced until the opening of the casino in accordance with the Company’s policy, and the portion assigned to gaining control of the development processes would have been amortized to expense over the period of development. Instead, the entire cost is being amortized over the combined development and operating period. Management believes that such treatment produces a proper matching of expense to all such periods and likely produces results substantially similar to those that would have been achieved had the cost been bifurcated between the two types of rights. The costs that are being expensed as incurred, on the other hand, are unrelated to the cost of acquiring any intangible contractual rights but rather represent, among others, primarily costs of servicing such rights and other period costs associated with project identification and recruitment.

General

RESPONSE: The Company has given effect in its interim condensed consolidated financial statements (and the separate statements of Stockman’s) presented in the amendment as of and for the six months ended June 30, 2006, to all applicable changes made to the annual financial statements in response to the Staff’s comments. In determining which among the changes made to the annual

Securities and Exchange Commission

Attention: Joe Foti

Page 11

financial statements are applicable to the interim financial statements, the Company has given due consideration to, and in most cases used, the condensed format permitted by Item 310(b)(1) of Regulation S-B.

Unaudited Interim Condensed Consolidated Financial Statement of Full House Resort, Inc.

Unaudited Condensed Consolidated Balance Sheet, page F-l6

RESPONSE: As discussed in the response to comment 10 above, the cumulative preferred stock dividends will be declared and paid in the foreseeable future only out of available proceeds and only if and when the offering goes effective as planned. Accordingly, since neither the dividend nor the proposed acquisition will occur without a successful offering, the Company believes it would likewise be misleading, as well as inconsistent with the purpose of the separate pro forma financial presentation, to include the dividend while omitting the offering. It is the Company’s understanding that the Staff generally approves including such offerings in pro forma presentations made pursuant to Item 310 (d)(ii) of Regulation S-B (or Article 11 of Reg. S-X) when the underwriting arrangement is on a “firm commitment” basis, which is the case in this instance. Accordingly, no changes have been made for this matter in either the annual or interim historical consolidated financial statements or in the pro forma financial statements presented in the amendment.

Unaudited Condensed Consolidated Statements of Cash Flows, page F-18

RESPONSE: It is the Company’s understanding that this detail is not required in interim condensed financial statements presented in SEC filings pursuant to Item 310(b)(1)(iii) of Regulation S-B and set forth more fully in Reg. S-X, Rule 10-01(a)(4)), which states, among other things, that “[t]he statement of cash flows may be abbreviated starting with a single figure of net cash flows from operating activities.” Accordingly, the Company has not made the requested change for this matter.

Securities and Exchange Commission

Attention: Joe Foti

Page 12

Note 13— Subsequent Events

RESPONSE: As described on page 57, this agreement was executed in September and additional disclosure regarding the transaction has been added to the notes to the financial statements as a subsequent event on page F-23.

Stockman’s Casino (Stockman’s) Financial Statements

Note 2- Summary of Significant Accounting Policies

Investments, page F-26

RESPONSE: The Staff’s attention is directed to the disclosure in Note 2 to Stockman’s financial statements, including the updated interim financial statements as of and for the six months ended June 30, 2006, presented in the amendment as of and for the six months ended June 30, 2006, stating that substantially all of its investments are in certificates of deposit (except for $58,870 or 2.5% in marketable equity securities at December 31, 2005). These are typical certificate of deposits that are, in substance, time deposits with a bank and, as such, according to Question 6 of a FASB Staff Implementation Guide issued in

Securities and Exchange Commission

Attention: Joe Foti

Page 13

1995 entitled “Accounting for Certain Investments in Debt and Equity Securities: Questions and Answers” (Current Text I80.807), do not meet the applicable definition of “debt securities” and, therefore, are not subject to the disclosure or other provisions of SFAS No. 115. The other accounting policy disclosures in Note 2 to Stockman’s financial statements, as originally filed, relate only to the insignificant $58,870 in marketable securities at December 31, 2005, and have been clarified in the amendment to so indicate.

Note 4— Related Party Transactions, page F-28

RESPONSE: Additional disclosure has been added to page F-31 to clarify that the lease rental expense is recognized on a straight line basis.

General

RESPONSE: Additional disclosure has been added to pages F-29 through F-32 to incorporate applicable interim period information in the financial statement notes. In determining which disclosures are applicable to the interim financial statements, as noted in the response to comment 16 above, the Company has given due consideration to and, in some cases, used the condensed format permitted by Item 310(b)(i) of Regulation S-B.

Unaudited Pro Forma Consolidated Financial Information, page F-30

RESPONSE: The requested disclosures have been added to pages 3, 20, 21 and F-33 with a placeholder for the net proceeds to be completed once a price range has been determined.

Securities and Exchange Commission

Attention: Joe Foti

Page 14

RESPONSE: The disclosure has been revised on pages 3, 21 and F-33 and the pro formas have been prepared accordingly.

Unaudited Consolidated Pro Forma Statements — Accounting Treatment on Stockman Acquisition, page F-31 and F-34 (Note 3)

RESPONSE: Additional disclosure regarding the recognition of goodwill has been added to footnote 5 on page F-38. The Company is not acquiring a license as part of the Stockman’s transaction. Licenses are issued to the operators (i.e., owners and certain key management executives), not the property, and are not transferable from one operator to another. Gaming licenses in Nevada and many other regulatory jurisdictions grant the privilege or right to do business for an unlimited period of time, so long as there is compliance with the applicable rules and regulations (including the periodic payment of gaming fees and taxes). The initial costs of obtaining such licenses ordinarily include fees for professional services but consist primarily of the cost of reimbursing the regulator for its comprehensive investigations of the backgrounds of the proposed owners and key management executives. There are no license renewal costs, per se, in Nevada, only periodic fees and taxes, which are expensed when incurred. Therefore, license costs to be incurred in connection with the acquisition by the Company, as new owners, and any new key management executives, will be capitalized (at

Securities and Exchange Commission

Attention: Joe Foti

Page 15

cost) when incurred and, accordingly, not amortized but, as indefinite life intangibles, subjected to impairment reviews pursuant to SFAS No. 142. Such costs, as best can be estimated at this time ($400,000 to $450,000), are reflected as acquisition costs in the pro forma financial information as part of adjustment 5 in the pro forma financial information and included in “deposits and other assets.” The liquor license is transferable but has been determined to have no more than a nominal value and therefore is not considered a separable intangible asset in the purchase price allocation.

Unaudited Consolidated Pro Forma Income Statements, pages F-32 and F-33

RESPONSE: As previously mentioned in the response to comment 10, above, the Company believes SAB Topic 1-B(3) is applicable only to post-balance sheet declarations of dividends that have actually occurred. In this case, the dividends were paid by the probable future acquisition target to its sole shareholder and appropriately reflected in its historical financial statements in the period declared and paid. No capital replacement of the dividends is contemplated. Accordingly, no changes have been made in the Stockman’s annual or interim historical financial statements, the pro forma financial information, or elsewhere in the amendment for this matter.

Securities and Exchange Commission

Attention: Joe Foti

Page 16

RESPONSE: Additional disclosure and adjustments regarding the pro forma earnings per share have been added on pages F-33 through F-37 to clarify the treatment of the dividend.

RESPONSE: The pro forma per share data has been revised to reflect the additional six million shares from the offering. See pages F-33 and F-37.

Unaudited Consolidated Pro Forma Balance Sheet, page F-31

Unaudited Consolidated Pro Forma Income Statement, page 32

Unaudited Consolidated Pro Forma Income Statement, page F-33

RESPONSE: The pro forma financial statements have been revised to separately present adjustments in two columns as requested.

RESPONSE: Additional disclosure has been provided on pages F-34 through F-38 to present adjustments individually.

Securities and Exchange Commission

Attention: Joe Foti

Page 17

Notes to Unaudited Pro Forma Consolidated Financial Statements, page F-34

RESPONSE: Additional disclosure has been provided on page F-37 regarding the deposits and the acquisition of land and buildings in connection with our purchase of the stock of Stockman’s. The $6,810,233 associated with the required transfer of land and buildings owned personally by the owner of Stockman’s is included in the amounts presented for the assets acquired on page F-37.

RESPONSE: Additional disclosure regarding the source of funds for the acquisition has been added on page F-37.

RESPONSE: Additional disclosure regarding the estimated debt financing has been provided on page F-37.

RESPONSE: Additional disclosure regarding the amount and uses of the equity proceeds has been provided on page F-37.

Securities and Exchange Commission

Attention: Joe Foti

Page 18

RESPONSE: Additional disclosure has been provided regarding the allocation of the purchase price for Stockman’s in footnote 5 on pages F-37 and F-38. The capitalized costs and related fair values were derived from a May 2006 appraisal by an independent real estate appraiser/consultant.

RESPONSE: Additional disclosure has been provided regarding depreciation in footnote 6 on page F-38.

RESPONSE: Additional disclosure regarding interest expense and amortization of loan fees has been provided in footnote 7 on page F-38.

RESPONSE: Additional disclosure regarding rental payments has been added in footnote 8 on page F-38.

RESPONSE: Additional disclosure regarding income tax expense has been provided in footnote 9 on page F-38.

Securities and Exchange Commission

Attention: Joe Foti

Page 19

RESPONSE: Additional disclosure regarding the purchase price adjustment has been added on page F-37. The adjustment amount, if any, will be included in the cost of the acquired entity. No additional equities will need to be issued as the funding amount includes sufficient proceeds to cover the contingency. The amount will not need to be held in escrow because the adjustment will be readily determinable.

General

RESPONSE: The interim financial statements and other financial data have been updated throughout the prospectus.

RESPONSE: Signed consents from the requisite independent public accountants will be included with each amendment.

* * * * *

Securities and Exchange Commission

Attention: Joe Foti

Page 20

Please call the undersigned with any questions or comments you may have regarding this letter. In addition, please send all written correspondence directly to the undersigned at Greenberg Traurig, P.A., 1221 Brickell Avenue, Miami, Florida 33131, telecopy (305) 579-0717, with copies to Barth Aaron, the Company’s General Counsel, at 4670 S. Fort Apache Road, Suite 190, Las Vegas, Nevada 89147, telecopy (702) 221-8101.

Very truly yours,

/s/ Michele L. Keusch

Michele Keusch