The problem of forming validation regions or gates for new sensor measurements obtained when tracking targets in clutter is considered. Since the gate size is an integral part of the data association filter, this paper is intended to describe a way of estimating the gate size via the performance of the data association filter. That is, the gate size can be estimated by looking for the optimal performance of the data association filter. Simulations show that this estimation method of the gate size offers advantages over the common and classical estimation methods of the gate size, especially in a heavy clutter and/or false alarm environment.