SecProbe.io

Mail Stop 3561         July 9, 2010  Via Fax & U.S. Mail

 Mr. Jon Feltheimer Chief Executive Officer Lions Gate Entertainment Corp. 1055 West Hastings Street Suite 2200 Vancouver, British Columbia V6E 2E9

Re: Lions Gate Entertainment Corp.
 Form 10-K for the year ended March 31, 2010
Filed June 1, 2010
 File No. 1-14880

Dear Mr. Feltheimer:

We have reviewed your filing and have th e following comments.  We think you should
revise your future filings in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your re sponse.  In some of our
comments, we may ask you to provide us wi th supplemental information so we may
better understand your disclosure.  After reviewing this info rmation, we may or may not
raise additional comments.

Please understand that the purpose of our revi ew process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Please respond to confirm that such comments w ill be complied with, or, if certain of the
comments are deemed inappropriate, advise th e staff of your reas on.  Your response
should be submitted in electronic form, under the label “corresp” with a copy to the staff.
Please respond within ten (10) business days.

Mr. Jon Feltheimer
Lions Gate Entertainment Corp. July 9, 2010 Page 2

Item 7.  Management’s Discussion and Analys is of Financial Condition and Results of
Operations

Critical Accounting Policies, page 46

1. We note your section on critical accounting policies.  It appears that the items
included are a mere repetition of your Significant Accounting Policies section.  Pursuant to FR-60, this sect ion is intended to focus on the sensitivity aspects of
your critical accounting policies, that is, the likelihood that materially different amounts would be reported under different conditions or assumptions.  In making
disclosures under FR-60, registrants need not repeat information that is already included in the financial statements or othe r sections of the filing.  Please revise
your disclosures in future filings accordingly.
 Net Loss, page 61

2. We note from the discussion on page 61 of  MD&A that net loss attributable to
noncontrolling interest for the year ended March 31, 2010 was $8.7 million compared to nil for the fi scal year ended March 31, 2009. Please revise MD&A in
future filings to explain the facts or circumstances responsible for the increase in the loss attributable to th e noncontrolling interest duri ng the year ended March 31,
2010.
 Item 7A. Quantitative and Qualitative Disclosures About Market Risk,  page 79

3. We note from the discussion in Item 7A that the company has exposure to cash flow risk due to changes in  market interest rates related to your  interest-bearing
debt, production loans and subordinated notes and othe r financing obligations.
Even though we note that you disclose the a dditional increase in interest expense
resulting from a quarter point increase in  rates in Risk Factors on page 25, please
revise the Company’s disclosure regarding Quantitative and Qualitative disclosures about Market in  future filings  to include the quantitative disclosures
required about interest rate risk in one of the suggested formats outlined in Item 305(a)(1) of Regulation S-K.
 Note 2.  Significant Accounting Policies,

 (v) Recent Accounting Pronouncements, page F-13

4. We note from your disclosure, that th e Company will adopt new accounting
guidance relative to variable interest en tities effective beginning in fiscal 2011,
and as a result of the Company’s review  and its current business and ownership
structure of the TV guide Network, the Company will no longer be required to
consolidate the TV Guide network eff ective April 1, 2010. Please explain to us

Mr. Jon Feltheimer
Lions Gate Entertainment Corp. July 9, 2010 Page 3
and expand your disclosures in the notes to  the Company’s financial statements in
future filings to explain in further detail why the Company will no longer be required to consolidate this entity unde r the new accounting guidance for variable
interest entities. We may have furthe r comment upon review of your response.
 Note 7. Finite-Lived Intangible A ssets and Other Assets, page F-17

5. We note from your disclosures included in Note 7 that the Company’s equity in
earnings of Studio 3 Partners, LLC was si gnificant in relation to the Company’s
results of operations for fiscal 2010. We also note that its financial statements
have been included in Exhibit 99.1 to Form  10-K.  Please revise future filings to
include in the notes to the financial statements summarized financial information for this investee as required by Rule 4-08(g) of Regulati on S-X and ASC Topic
323-10-50-3.
 Note 15. Capital Stock, page F-29

Stock Options

6. We note from the disclosure in footnote (2) to the table on page F-31 that in
connection with the acquisition of Mandate  Pictures, two executives entered into
employment agreements with LGF and were granted an aggregate of 600,000
stock options, 200,000 of which vested and 400,000 options of which are vesting
over a one-to three year period. Please tell us how the Company accounted for
these stock option grants in its financia l statements and explain the basis or
rationale for the treatment used. We may have further comment upon receipt of your response.
 Note 24. Quarterly Financial Data (Unaudited)

7. We note from the disclosures included in  Note 24 that the Company’s quarterly
results of operations fluctuated signif icantly during both fi scal 2009 and fiscal
2010. To the extent these fluctuations in the Company’s quarte rly results are due
to any material unusual items that occurr ed during the periods, please revise the
notes to the financial statements in futu re filings to describe the nature and
amounts of such items. Refer to the gui dance outlined in Item 302 of Regulation
S-K.
 Other

8.  We urge all persons who are responsible  for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all information
required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision.  Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the

Mr. Jon Feltheimer
Lions Gate Entertainment Corp. July 9, 2010 Page 4
disclosures they have made.

In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
‚ the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
‚ staff comments or changes to disclosu re in response to staff comments do
not foreclose the Commission from taking any action with respect to the filing;
and
‚ the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or  any person under the federal securities
laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 You may contact Effie Simpson at (202) 551-3346, or the undersigned if you have
questions regarding comments on the financial statements and related matters.  Please
contact John Stickel at (202) 551-3324 with any other questions.

Sincerely,

Linda Cvrkel Branch Chief
Via Fax: James Keegan, CFO    (310) 388-1306