SecProbe.io

Mail Stop 3561

March 3, 2017

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

Re: Lions Gate Entertainment Corp.
 Form 10-K for the Fiscal Year Ended March 31, 2016
Form 10 -Q for the Fiscal Quarter Ended December 31, 2016
Form 8 -K furnished February 8, 2017
File No. 001 -14880

Dear Mr. Barge :

We have limited our review  of your filing  to the financial statements and related
disclosures 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 these comments  within ten busine ss days b y 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.

Form 10 -Q for the Fiscal Quarter Ended December 31, 2016

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Results of Operations

Media Networks Supplemental Pro Forma F inancial Information , pages 69 and 84

1. We note that you have included pro forma information for the Media Network segment
for both the three and nine months ended December 31, 2016.  You disclose that the
effects of purchase accounting do not affect segmen t profit and therefore such
adjustments are not included.  In this regard, please provide further details on the nature
of the expenses included within direct operating expenses, distribution and marketing
expenses, and general and administrative expenses given that your pro forma financial

James W. Barge
Lions Gate Entertainment Corp.
March 3, 2017
Page 2

 statements for the Starz acquisition furnished in an 8 -K on December 9, 2016 reflect
adjustments to eliminate intercompany revenue between Lions Gate and Starz, as well
adjustments concerning general and administrative e xpenses in adjustments A14 through
A17 which appear to impact segment profit.  We may have further comment upon receipt
of your response.

Form 8 -K furnished February 8, 2017

Exhibit 99.1

2. Please revise your reconciliation of Adjusted OIBDA to operating loss on page 11 to
begin with the GAAP measure, operating loss rather than non -GAAP measure, Adjusted
OIBDA.  Similarly, please revise your reconciliation of Adjusted EBITDA on page 18 to
begin with net income (loss).  Refer to Question 102.10 of the updated Non -GAAP
Compliance and Disclosure Interpretations issued on May 17, 2016.

3. In addition, please revise your adjustments so that you are not adjusting GAAP measures
by adjusted items.  In this regard, we note that you have adjustments to operating loss for
“adjusted depreciation and amortization” and “adjusted share -based compensation
expense” which are also non -GAAP measures.  Each adjustment should be listed and
explained separately.  Ple ase revise accordingly.

4. It would appear as though the information presented on pages 13 through 15 represent
pro forma information derived from combining the Starz and Lions Gate information
prior to the merger at the beginning of your fiscal year 2017.  Please revise to
appropriately label this information as “pro forma.”

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Heather Clark at 202 -551-3624 if you have questions regarding
comments on the financial statements and related matters.  Please contact me at 202 -551-3379
with any other questions.

Sincerely,

 /s/ Melissa Raminpour

Melissa Raminpour
Branch Chief
Office of Transportation and Leisure