UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4561 DIVISION OF CORPORATION FINANCE February 28, 2012 Andrew Hagopian III MGM Resorts International
[email protected] Re: MGM Resorts International Incoming letter dated January 10,2012 Dear Mr. Hagopian: This is in response to your letters dated January 10,2012, February 16,2012, and February 23,2012 concerning the shareholder proposal submitted to MGM Resorts by the New York City Employees' Retirement System, the New York City Teachers' Retirement System, the New York City Fire Department Pension Fund, the New York City Police Pension Fund, and the New York City Board ofEducation Retirement System. We have also received letters on the proponents' behalf dated February 14,2012 and February 22, 2012. Copies ofall ofthe correspondence on which this response is based will be made available on our website at http://www.sec.gov/divisions/cOl:pfmlcf noactionlI4a-8.shtml. For your reference, a briefdiscussion ofthe Division's informal procedures regarding shareholder proposals is also available at the same website address. Sincerely, TedYu Senior Special Counsel Enclosure cc: Janice Silberstein The City ofNew York Office ofthe Comptroller
[email protected] February 28, 2012 Response of the Office ofChiefCounsel Division of Corporation Finance Re: MGM Resorts International Incoming letter dated January 10,2012 The proposal requests that the board issue a report to shareholders on the company's sustainability policies and perfonnance, including multiple, objective statistical indicators. IdUrther specifies that the report should include the company's defmition ofsustainability, as well as a company-wide review ofcompany policies, practices arid indicators related to measuring long-tenn social and environmental sustainability.