December 14, 2018

VIA EDGAR

Wilson K. Lee

Senior Staff Accountant, Office of Real Estate & Commodities

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-7010

Re: Las Vegas Sands Corp.

Form 10-K for the fiscal year ended December 31, 2017

Form 10-Q for the quarterly period ended March 31, 2018

Filed February 23, 2018 and April 27, 2018, respectively

File No. 1-32373

Dear Mr. Lee:

Las Vegas Sands Corp. (“we,” “our” or the “Company”) hereby responds to the comment set forth in the comment letter of the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) dated November 30, 2018 (the “Comment Letter”) relating to the above referenced SEC filings.

For the convenience of the Staff, the Company has restated in this letter the comment in the Comment Letter in italics, followed by the Company’s response. All references to page numbers and captions (other than those in the comments) correspond to the page numbers in the relevant SEC filing.

Corporate Headquarters

3355 Las Vegas Blvd. South, Las Vegas, Nevada 89109

The Venetian | The Palazzo | Sands Expo | Sands Bethlehem | Sands Macao | The Venetian Macao | Four Seasons Hotel Macao The Plaza Macao | Sands Cotai Central | The Parisian Macao | Marina Bay Sands

Wilson K. Lee

Securities and Exchange Commission

December 14, 2018

Page 2

Form 10-Q for the quarterly period ended March 31, 2018

Financial Statements

Note 2 - Revenue, pages 10-12

1. We have considered your response and note that you include operating metrics such as win and hold percentage to provide additional details of your financial results from an operating perspective to highlight trends and further explain your financial results. As you have disclosed, win and hold percentages are calculated before discounts, commissions, deferring revenue associated with your loyalty programs and allocating casino revenues related to goods and services provided to patrons on a complimentary basis. To the extent that amounts related to the loyalty program and provided on a complimentary basis are material to the operating metric calculation, please revise future filings to parenthetically disclose such amounts in totality for each respective operating metric.

We acknowledge the Staff's comment.  To the extent the amounts related to our loyalty programs and provided on a complimentary basis become material to the operating metric calculation, we will revise our future filings to parenthetically disclose such amounts in totality.

Wilson K. Lee

Securities and Exchange Commission

December 14, 2018

Page 3

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The Company believes the foregoing is fully responsive to the Comment Letter. Please let us know if you have any questions by contacting the undersigned at (702) 733-5503.

Sincerely,

/s/ Lawrence A. Jacobs

Lawrence A. Jacobs

Executive Vice President, Global General Counsel and Secretary

Las Vegas Sands Corp.

cc: Howard Efron, SEC

Brian V. Breheny, Skadden, Arps, Slate, Meagher & Flom LLP