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May 22, 2019

VIA EDGAR

Division
of Corporation Finance

Office of
Transportation and Leisure

U.S.
Securities and Exchange Commission

Washington,
D.C. 20549

Attn:
Heather Clark

           Melissa
Raminpour

Re:  Hasbro, Inc.

        Form 10-K for the Fiscal Year Ended December 30, 2018

        Filed February 26, 2019

        File No.  001-06682

Dear Ms. Clark and Ms. Raminpour:

This letter is submitted on behalf of Hasbro, Inc. (the “Company”),
in response to the comments that you have provided on behalf of the staff of
the Division of Corporation Finance (the “Staff”) of the Securities and
Exchange Commission (the “SEC”) in your letter dated May 9, 2019.

For your convenience, we have set forth the original comments from
your letter in bold and italicized typeface to which we are responding.

Form 10-K for the Fiscal Year
Ended December 30, 2018

Financial Statements

Notes to the Consolidated
Financial Statements

(22) Quarterly Financial Data
(Unaudited – see accompanying accountants’ report), page 94

1. During the fiscal years ended
December 30, 2018 and December 31, 2017, the quarterly data shows significant
fluctuations in operating results between the quarters. Specifically, there are
large variations in revenues, operating profit, and net earnings (loss) for all
quarters. Please revise to add a discussion of any unusual or infrequently
occurring items during each quarter, which may have contributed to the
significant fluctuations in operating results. Refer to Item 302(a)(3) of
Regulation S-K.

Response

The Company acknowledges the Staff’s comment. The Company
respectfully notes that disclosure of unusual or infrequently occurring items
has been made throughout the Form 10-K for the fiscal year ended December 30,
2018 (“Form 10-K”) including the Notes to the consolidated financial
statements. These items include:

·
 Bad debt charges, royalty expense and inventory obsolescence and
other costs related to the Toys “R” Us bankruptcy and liquidation, as disclosed
in Note 2. Revenue Recognition and in Item 7, Management’s Discussion and
Analysis of Financial Condition and Results of Operations (page 33);

·
 Goodwill and intangible asset impairment charges, as disclosed in
Note 1. Summary of Significant Accounting Policies, Note 5. Goodwill and
Intangibles, Item 1, Business (page 4), Item 1A, Risk Factors (pages 24 and 27) and Item 7, Management’s Discussion and
Analysis of Financial Condition and Results of Operations (page 32);

·
 The impact of tax reform, as disclosed in Note 11. Income Taxes
and Item 7, Management’s Discussion and Analysis of Financial Condition and
Results of Operations (page 33); and

·
 Restructuring charges, as disclosed in Note 19. Restructuring
Actions, Item 1, Business (page 4), Item 1A, Risk Factors (Page 23) and Item 7,
Management’s Discussion and Analysis of Financial Condition and Results of
Operations (page 32).

In future
filings, to the extent appropriate, the Company will undertake to include such
disclosures to the “quarterly data” Note in the annual consolidated financial
statements. By way of example, using our Form 10-K for the fiscal year ended
December 30, 2018 as a model, in future filings, if appropriate, we intend to
include footnotes related to Net earnings (loss) to the quarterly data table
such as the following:

(22)         Quarterly Financial Data (Unaudited)

  Quarter

  First

  Second

  Third

  Fourth

  Full Year

  2018

  Net revenues

  $

  716,341

  904,458

  1,569,686

  1,389,161

  4,579,646

  Operating profit
  (loss)

  (80,419)

  87,588

  313,336

  10,547

  331,052

  Earnings
  (loss)before income taxes

  (88,388)

  68,124

  295,794

  (5,128)

  270,402

  Net earnings (loss)
  (a)

  (112,492)

  60,299

  263,861

  8,766

  220,434

  Per common share

  Net earnings (loss)

  Basic

  $

  (0.90)

  0.48

  2.08

  0.07

  1.75

  Diluted

  (0.90)

  0.48

  2.06

  0.07

  1.74

  Market price

  High

  $

  103.39

  93.00

  109.60

  107.57

  109.60

  Low

  83.56

  79.00

  91.70

  76.84

  76.84

  Cash dividends
  declared

  $

  0.63

  0.63

  0.63

  0.63

  2.52

  Quarter

  First

  Second

  Third

  Fourth

  Full Year

  2017

  Net revenues

  $

  849,663

  972,506

  1,791,502

  1,596,111

  5,209,782

  Operating profit

  78,343

  99,984

  360,944

  271,088

  810,359

  Earnings before
  income taxes

  70,837

  86,886

  349,841

  278,586

  786,150

  Net earnings (loss)
  (b)

  68,599

  67,723

  265,583

  (5,298)

  396,607

  Per common share

  Net earnings (loss)

  Basic

  $

  0.55

  0.54

  2.12

  (0.04)

  3.17

  Diluted

  0.54

  0.53

  2.09

  (0.04)

  3.12

  Market price

  High

  $

  101.08

  113.49

  116.20

  99.17

  116.20

  Low

  77.20

  94.76

  91.57

  87.92

  77.20

  Cash dividends
  declared

  $

  0.57

  0.57

  0.57

  0.57

  2.28

(a)
 Net earnings (loss) for the 2018 quarters include the impact of
the following items:

·
 In the first quarter of 2018, Toys"R"Us announced a
liquidation of its U.S. operations, as well as other retail impacts around the
globe. As a result, the Company recognized incremental bad debt expense on
outstanding Toys"R"Us receivables, royalty expense, inventory obsolescence
as well as other related costs of $70.4 million ($61.4 million after-tax). In
the fourth quarter of 2018, the Company made adjustments to the charges
previously recorded based on its final settlement with Toys"R"Us,
resulting in a benefit of $10.0 million ($8.5 million after-tax).

·
 In the first quarter of 2018, the Company incurred $17.3 million
($15.7 million after-tax) of severance charges, primarily outside the U.S., related
to actions associated with a new go-to-market strategy designed to be more
omni-channel and e-commerce focused. Additionally, in the fourth quarter of
2018, the Company recorded an additional $72.0 million ($62.2 million
after-tax) of severance charges.

·
 In the fourth quarter of 2018, the Company incurred a goodwill
impairment charge related to its Backflip business of $86.3 million, as well as
impairments of certain definite-lived intangible assets totaling $31.3 million.
These charges totaled $96.9 million on an after-tax basis.

·
 Throughout 2018, the Company made adjustments to provisional U.S.
Tax Reform amounts recorded in the fourth quarter of 2017 based on additional
regulations issued, amounting to charges of $47.8 million the first quarter of
2018, a benefit of $17.3 million in the third quarter of 2018 and charges of
$10.2 million the fourth quarter of 2018.

(b)
 Net earnings (loss) for the fourth quarter of 2017 included the
impact of the following items:

·
 In accordance with the Tax Act, the Company recorded a provisional
tax expense of $316.4 million, the period in which the legislation was
enacted.

2. Additionally, tell us if you considered separately stating such
material expenses separately on the face of the income statement.  Please refer
to Rule 5-03(b)(3) and (6) of Regulation S-X.

The Company acknowledges the Staff’s comment and notes that the
Company did not believe it was necessary to state the charges indicated above
separately on the face of the consolidated statement of operations. In making
the determination that such presentation was not required, the Company
considered that total bad debt expense of $49.0 million, goodwill and
intangible asset impairment expense of $117.6 million and restructuring expense
of $89.3 million were recorded in Selling, distribution and administration
expense. These expenses represented 3.8%, 9.1% and 6.9%, respectively, of
Selling, distribution and administration expense, or 1.1%, 2.8% and 2.1% of
total operating expenses. Given the materiality of such expenses and the
related percent of the line items presented on the face of the consolidated
statement of operations, the Company determined that disclosure in the notes to
the consolidated financial statements and elsewhere in the 10-K was
appropriate.

3. Please tell us the significance of the reference to the
accountant’s report in note 22 given that we note no reference to quarterly
data in the report on page 53. In this regard, it appears you should revise to
remove the reference "see accompanying accountants' report" since the
footnote is marked unaudited.

The Company acknowledges the Staff’s comment and notes that the
Company inadvertently referred to the accountant’s report based on
misinterpretation of disclosure guidance. The Company will update

future filings to remove this reference.

If you have any questions or desire further information regarding
the Company’s responses, please contact me at (401) 727-5500.

Sincerely,

/s/ Deborah Thomas

Deborah Thomas

Executive Vice President and Chief Financial Officer