Correspondence 0001193125-25-053523 from STARZ ENTERTAINMENT CORP /CN/ (STRZ)
STARZ ENTERTAINMENT CORP /CN/
Date: March 13, 2025 · CIK: 0000929351 · Accession: 0001193125-25-053523
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File numbers found in text: 333-282630
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CORRESP 1 filename1.htm CORRESP [Letterhead of Wachtell, Lipton, Rosen & Katz] March 13, 2025 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Energy & Transportation 100 F Street, NE Washington, D.C. 20549 Attention: Robert Shapiro Joel Parker Cara Wirth Taylor Beech Re: Lions Gate Entertainment Corp. Amendment No. 4 to Registration Statement on Form S-4 Filed February 24, 2025 File No. 333-282630 Ladies and Gentlemen: On behalf of our client, Lions Gate Entertainment Corp. (“Lionsgate”), we are providing Lionsgate’s response to the comments of the Staff (the “Staff”) of the Division of Corporation Finance (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) set forth in its letter, dated March 7, 2025, with respect to the above-referenced Registration Statement on Form S-4 (the “Registration Statement”). Lionsgate has filed via EDGAR Amendment No. 5 to the Registration Statement (the “Amended Registration Statement”), which reflects Lionsgate’s response to the comments received by the Staff and certain updated information. For the Staff’s convenience, the text of the Staff’s comment is set forth below in bold, followed by Lionsgate’s response. Terms not otherwise defined in this letter shall have the meanings set forth in the Amended Registration Statement. Amendment No. 4 to Registration Statement on Form S-4 Filed February 24, 2025 Cover Page Please revise footnote ** on the cover page to clarify that Starz Entertainment Corp. will be the issuer of the Starz common shares that are being registered. Response : Lionsgate has revised footnote ** on the cover page of the Amended Registration Statement in response to the Staff’s comments. * * * March 13, 2025 Page 2 If you have any questions related to this letter, please do not hesitate to contact Fabiola Urdaneta at (212) 403-1121. Sincerely By: /s/ Fabiola Urdaneta Name: Fabiola Urdaneta Enclosures cc: Bruce Tobey Executive Vice President and General Counsel Lions Gate Entertainment Corp. Adrian Kuzycz Executive Vice President and Associate General Counsel Lions Gate Entertainment Corp. David Shapiro Wachtell, Lipton, Rosen & Katz Mark A. Stagliano Wachtell, Lipton, Rosen & Katz