SecProbe.io

Mail Stop 3561
February 22, 2016

James W. Barge
Chief Financial Officer
Lions Gate Entertainment Corp.
2700 Colorado Avenue , Suite 5000
Santa Monica, CA 90404

Re: Lions Gate Entertainment Corp.
 Form 10-K for the Fiscal Year Ended March 31, 2015
Filed May 21, 2015
File No. 001 -14880

Dear Mr. Barge :

We have reviewed your filing an d 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Schedule II. Valuation and Qualifying Accounts, page 80

1. For the year ended March 31, 2015 we note that the amount charged to expense for the
returns and allowances reserve was much less than actual returns.  Please tell us why
there is such a difference.

Notes to Audited Consolidated Financial Statements

12. Income Taxes, page F -36

2. We note that although foreign income before tax was 68% of your consolidated pretax
income for 2015, the effective income tax rate on this income was only about 2%.  We
also note from the reconciliation between income taxes com puted at a Federal statutory
rate of 35% and the effective income tax rate that foreign and provincial operations
subject to different income taxes significantly reduced your effective income tax rate.
Please explain to us the nature of this significant  reconciling item including the nature of

James W. Barge
Lions Gate Entertainment Corp.
February 22, 2016
Page 2

 any foreign jurisdictions that contribute a significant amount of income with a low or no
tax rate.  Also, please explain to us why foreign operations appear to have a more
significant effect in decreasing the tax rate in fiscal 2015 than in prior years.

14. Segment Information, page F -39

3. It appears from your disclosures on page 4 and elsewhere that both Motion Pictures
revenue and Televis ion Production revenue include revenue derived from several
different sour ces.  Please revise to separately disclose revenue for each product or service
or group of similar product or services as required by ASC 280 -10-50-40.

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 Exchange 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 Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiate d by
the Commission or any person under the federal securities laws of the United States.

You may contact Melissa Gilmore  at (202) 551 -3777 or Claire Erlanger at (202) 551 -
3301 with any questions.

Sincerely,

 /s/ Melissa Raminpour

Melissa Raminpour
Branch Chief
Office o f Transportation and Leisure