SecProbe.io

January 3, 2013

Via E -mail
James Keegan
Chief Financial Officer
Lions Gate Entertainment Corp.
1055 West Hastings Street , Suite 2200
Vancouver, British Columbia V6E 2E9

Re: Lions Gate Entertainment Corp.
 Form 10-K/A for the fiscal year ended March 31, 201 2
Filed June 22 , 2012
File No. 001-14880

Dear Mr. Keegan :

We have reviewed your filing  and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within 10 business days by confirming that you will revise
your document in future filings and providing any requested information.   If you do not believe
our comm ents apply to your facts and circumstances , please tell us why in your response.

After reviewing the information you provide in response to these  comments, we may
have additional comments.

Form 10 -K/A for the fiscal year ended March 31, 2012

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
5
Liquidity and Capital Resources, page 35

1. We note your disclosure on page F -44 that U.S. income taxes were not provided on
undistributed earnings from Australian  and UK subsidiaries as t hose earnings are
considered to be permanently reinvested in accordance with accounting guidance.   In this
regard, please revise your liquidity section of MD&A to disclose  a statement that the
company would need to accrue and pay t axes if repatriated; and a statement that the
company does not intend to repatriate the funds .  Also, please revise Note 17 to disclose
the cumulative amount of earnings of foreign subsidiaries in which U.S. income taxes

James Keegan
Lions Gate Entertainment Corp .
January 3, 2013
Page 2

 have not been provided because they  are considered to be permanently reinvested
pursuant to ASC 740 -30-50.

Financial Statements, page F -1
Consolidated Statements of Cash Flows, page F -6

2. We note noncash investing and financing activities in recent years such as conversion of
debt, issuan ce of stock for acquisitions, and issuance of shares for services.  In this
regard, please revise your statements of cash flows in future filings to present the
schedule of noncash investing and financing activities required by ASC 230 -10-50-3.

Notes to C onsolidated Financial Statements, page F -7
9. Corporate Debt, page F -22

3. We note that your credit facility, term loan, and notes are subject to compliance with
covenants as outlined in each agreement.  Please revise the notes to your financial
statements and liquidity discussion in future filings to disclose whether you were in
compliance with the covenants of each debt instrument as of your fiscal year end.

15. Acquisitions and Divestitures, page F -37
Summit, page F -37

4. We note your presentation of the supplemental pro forma information required by ASC
805-10-50-2 as it rela tes to the acquisition of Summit.  Please revise your footnote to also
disclose the nature and amount of any material, nonrecurring pro forma adjustments
directly attributable to the business combination included in reported pro forma revenue
and earnings in accordance with ASC 805 -10-50-2h.

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 the information the Securities Exchange Act of
1934 and all applicable Excha nge Act rules require.   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 disclosures they have made.

 In responding to our comments, please provide  a written 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 disclosure in response to staff comments do not foreclose
the Commissi on from taking any action with respect to the filing; and

James Keegan
Lions Gate Entertainment Corp .
January 3, 2013
Page 3

  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.

You may contact Heather C lark at 202 -551-3624 or Jean Yu at 202 -551-3305 if you have
questions regarding comments on the financial statements and related matters.  Please contact me
at 202 -551-3813 with any other questions.

Sincerely,

 /s/ Linda Cvrkel

 Linda Cvrkel
Branch Chief