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                             October 5, 2020

       Jason D. Robins
       Chief Executive Officer
       DraftKings Inc.
       222 Berkeley Street, 5th Floor
       Boston, Massachusetts 02116

                                                        Re: DraftKings Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed October 5,
2020
                                                            File No. 333-249299

       Dear Mr. Robins:

              We have reviewed your registration statement 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comment applies to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to this comment, we may have additional comments.

       Registration Statement on Form S-1, Filed October 5, 2020

       Summary of the Prospectus
       Recent Developments, page 1

   1.                                                   We note the following
disclosures on page 2 of your filing:

                                                              "Our financial
results for the three months ended September 30, 2020 are not yet
                                                            finalized. As of
the date of this preliminary prospectus, we expect to report unaudited
                                                            revenue for the
three months ended September 30, 2020 of between $131 million and
                                                            $133 million on a
U.S. generally accepted accounting principles (GAAP') basis, an
                                                            increase of
approximately 97% as compared with the three months ended September
                                                            30, 2019, and
approximately 41% as compared with the three months
                                                            ended September 30,
2019, after giving pro forma effect to the Business Combination
 Jason D. Robins
DraftKings Inc.
October 5, 2020
Page 2
           as if it had occurred on January 1, 2019 (in each case assuming a
midpoint of $132
           million for the three months ended September 30, 2020)."

             "Our online sports betting handle for the three months ended
September 30, 2020, is
           expected to have grown approximately 460% compared to the same
period last year,
           including online sports betting handle growth in New Jersey of
approximately 110%.
           Our iGaming handle for the three months ended September 30, 2020 is
expected to
           have grown approximately 335% compared to the same period last year,
including
           iGaming handle growth in New Jersey of approximately 150%."

      Please revise your registration statement to provide context for the your
preliminary
      estimates, including qualitative and/or quantitative disclosure. For
example, please
      provide estimates or narrative disclosure related to cost of revenue,
gross profit or gross
      margin, or other, similar results to provide context for your revenue
estimates. Further,
      considering your disclosure that "handle" is defined as "revenue . . .
generated from bets
      received from paid users," please provide context for your revenue growth
estimates by
      providing estimates for the growth in cost of revenue or other similar
measures related to
      the handle for online sports betting, online sports betting in New
Jersey, iGaming, and
      iGaming in New Jersey, respectively.

      We also note your statement that "these preliminary results for the three
months
      ended September 30, 2020, are not guarantees of future performance or
outcomes and . .
      . actual results may differ materially from those described above"
(emphasis added).
      Please remove your statement that the results may "materially" differ, or
remove the
      preliminary estimates from your registration statement.
       Please contact Katherine Bagley at (202) 551-2545 or Erin Jaskot at
(202) 551-3442 with
any questions.



                                                            Sincerely,
FirstName LastNameJason D. Robins
                                                            Division of
Corporation Finance
Comapany NameDraftKings Inc.
                                                            Office of Trade &
Services
October 5, 2020 Page 2
cc:       Scott D. Miller
FirstName LastName