DraftKings Inc. — Regulatory Filings 2021

Dec 8, 2021

CORRESP 1 filename1.htm

New Duke Holdco, Inc.

222 Berkeley Street, 5th Floor

Boston, Massachusetts 02116

December 8, 2021

VIA EDGAR

United States Securities and Exchange Commission Division of Corporation Finance

Office of Trade & Services 100 F Street, N.E. Washington, D.C. 20549.

Attention: Stacey Peikin; Jennifer López-Molina

Re: Acceleration Request for New Duke Holdco, Inc. Registration Statement on Form S-4 (File No. 333-260174)

To Whom It May Concern:

Pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, New Duke Holdco, Inc. (the “ Company ”) hereby requests that the effective date of the Company’s Registration Statement on Form S-4, File Number 333-260174 (the “ Registration Statement ”) be accelerated so that it will become effective at 4:00 P.M., New York City time, on December 9, 2021, or as soon as practicable thereafter.

Please contact Scott D. Miller of Sullivan & Cromwell LLP via telephone on (212) 558-3109 or via e-mail (millersc@sullcrom.com), as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

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Securities and Exchange Commission December 8, 2021
-2-

Sincerely,
New Duke Holdco, Inc.
By	/s/ R. Stanton Dodge
	Name:	R. Stanton Dodge
	Title:	Secretary

cc:
Jennifer López-Molina
(Securities and Exchange Commission)
Scott D. Miller
(Sullivan & Cromwell LLP)

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