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July 27, 2023
Kevin Benning
Property General Manager
Studio City International Holdings Limited
71 Robinson Road #04-03
Singapore 068895
Re: Studio City
International Holdings Limited
Form 20-F for the
Fiscal Year Ended December 31, 2022
Response dated July
13, 2023
File No. 001-38699
Dear Kevin Benning:
We have reviewed your July 13, 2023 response to our comment
letter and have the
following comment. In comment, we may ask you to provide us with
information so we may
better understand your disclosure.
Please respond to this 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 this comment, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
June 15, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 3. Key Information , page 10
1. We note your responses
to prior comments 3, 4 and 5. Please also provide the disclosure
requested at the outset
of Item 3.
Kevin Benning
FirstName
Studio CityLastNameKevin Benning
International Holdings Limited
Comapany
July NameStudio City International Holdings Limited
27, 2023
July 27,
Page 2 2023 Page 2
FirstName LastName
You may contact Eric McPhee at 202-551-3693 or Robert Telewicz at
202-551-3438 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Pearlyne Paulemon at 202-551-8714 or Brigitte Lippmann at 202-551-3713
with any
other questions.
Sincerely,
Division of
Corporation Finance
Office of Real Estate
& Construction