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Mailstop 3561
February  13, 201 8

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 Fiscal Year Ended March 31, 2017
Filed May 25, 2017
Form 10-Q for the Fiscal Period Ended December 31, 2017
Filed February 2, 2018
File No s. 001-14880

Dear Mr. Barge :

We have limited our review  of your filing s to the financial statements and related
disclosures and have the following comment s.  In our comment s, we may ask you to provide us
with information so we may better understand your disclosure.

Please respond to these comment s 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
comment s apply to your facts and circumstances, please tell us why in your response.

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

Form 10 -K for Fiscal Year Ended March  31, 201 7

Note 8 – Debt

1. We note from your risk factor disclosure on page 39 and in Note 8 that your Senior
Credit Facilities and the indenture that governs the 5.875% Sen ior Notes contain a
number of restrictive covenants, which includes your ability to pay dividends.  Please tell
us your consideration to disclose the amount of retained earnings or net income that is
restricted or free of restrictions for payment of divide nds pursuant to Rule 4 -08(e)(1) of
Regulation S -X.

James W. Barge
Lions Gate Entertainment Corp.
February  13, 201 8
Page 2

 Note  16 – Segment Information

Tabular Disclosure of Tangible Assets  by Geographic Locati on, page F -54

2. We are not able to reconcile your total tangible assets as disclosed here to the face of the
balance sheet.  Please tell us  and revise to disclose what is included in  the composition of
total tangible assets.  Please revise your future filings to exclude any intangible assets
from this disclosure , as applicable.  Refer to ASC 280 -10-50-41 and ASC 280-10-55-23.

Form 10 -Q for the Fiscal Period Ended December 3 1, 2017

Note 15 – Contingencies

Litigation , page 37

3. We note that you disclose several legal matters related to the Starz merger, and in some
instances, you indicate that you intend to vigorously defend the action.  It is not clear to
us which of these claims, if any, have had amounts accrued under ASC 450 -20-25-2 or if
there are any potential future payments deemed reasonably possible in addition to
amounts previously accrued.  Please revise your future filings to disclose the following
information for your loss contingencies in aggregate or individually: (1 ) the amount or
range of reasonably possible losses in addition to the amounts accrued or (2) a statement
that the reasonably possible losses cannot be estimated or are not material to your
financial statements.  Refer to ASC 450 -20-50-3 through 50 -5.  We also suggest that you
clarify the likely outcome using the language that is directly cited in ASC 450 -20 (e.g.
probable, reasonably possible, et al).  Please provide us with your proposed revisions.

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

You may contact Jim Dunn  at (202) 551 -3724 or me at (202) 551 -3379  with any
questions.

Sincerely,

 /s/ Melissa Raminpour

Melissa Raminpour
Branch Chief
Office of Transportation and Leisure