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CORRESP

 FOIA Confidential Treatment Request by

Ziff Davis, Inc. Pursuant to Rule 83 (17 C.F.R. 200.83)

*** - Information omitted and provided under separate cover to the Staff pursuant to Rule 83

Ziff Davis, Inc.

 360
Park Avenue South, 17th Floor

 New York, NY 10010

Via EDGAR

 December 30, 2024

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 Office of Technology

 100 F Street, N.E.

Washington, D.C., 20549

 Attention: Kathleen Collins and Megan
Masterson

 Re: Ziff Davis, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2023

Form 10-Q for the Quarterly Period Ended September 30, 2024

File No. 000-25965

Dear Ms. Collins and Ms. Masterson:

 This
letter is being furnished on behalf of Ziff Davis, Inc. (the “Company,” “we,” “us” or “our”) in response to the comments received from the staff of the Division of Corporation Finance (the “Staff”)
of the United States Securities and Exchange Commission (the “Commission”) by letter dated December 17, 2024, regarding the Company’s Annual Report on Form 10-K for the year ended
December 31, 2023 that was filed with the Commission on February 26, 2024 and the Company’s Quarterly Report on Form 10-Q for the quarter ended September 30, 2024 that was filed with the
Commission on November 8, 2024.

 The headings and numbered paragraphs of this letter correspond to the headings and paragraph numbers
contained in the comment letter, and to facilitate your review, the Company has reproduced the text of the Staff’s comments in italicized print below. Unless otherwise noted, references in this letter to page numbers and section headings refer
to page numbers and section headings in the 2023 Form 10-K, as indicated.

 Due to the commercially
sensitive nature of certain information contained in this response, this letter is also a request for confidential treatment of the bracketed portions of this response (designated by “[***]”) pursuant to the Commission’s confidential
treatment procedure under Rule 83 (17 C.F.R. §200.83). In accordance with Rule 83, the Response Letter has also been clearly marked with the legend “FOIA Confidential Treatment Request by Ziff Davis, Inc. Pursuant to Rule 83 (17 C.F.R.
200.83)” and each page is marked for the record with the identifying numbers and code “ZD-01” through “ZD-12.”

Form 10-K for the Fiscal Year Ended December 31, 2023

Notes to Consolidated Financial Statements

Note 18. Segment Information, page 107

 1. We
note from our December 17, 2024 conversation with the company, your current operating and reporting segments will change in the fourth quarter of fiscal 2024. You further indicated that you intend to aggregate three

 ZD-01

 FOIA Confidential Treatment Request by

Ziff Davis, Inc. Pursuant to Rule 83 (17 C.F.R. 200.83)

*** - Information omitted and provided under separate cover to the Staff pursuant to Rule 83

of your new operating segments into one reportable segment. Please provide us with an analysis that explains, in detail, how you determined your revised operating segments meet the aggregation
criteria in ASC 280-10-50-11.

Response: The Company respectfully acknowledges the Staff’s comment. The following provides information on the changes to our
operating segments during the fourth quarter of 2024, and our analysis of the aggregation criteria under ASC 280-10-50-1 for
three operating segments aggregated under one of our reportable segments.

 Changes to Operating Segments

In connection with the continued evolution of the Company’s management and reporting structure and the approach of the Chief Operating Decision Maker
(“CODM”) to making operating decisions, assessing performance, and allocating resources, the Company is now organized into five operating segments rather than nine operating segments.

We have determined our five operating segments in accordance with ASC 280-10-50-1. Applying that guidance we have determined our operating segments to be: (1) Technology & Shopping, (2) Gaming & Entertainment, (3) Health &
Wellness, (4) Connectivity and (5) Cybersecurity & Martech.

 The Company’s Chief Executive Officer (“CEO”), who we
determined to be the CODM, primarily views the organization as (i) a digital media company and (ii) as an internet company focused on cloud-based software services. Our operating segment structure was created as management of these
businesses has continued to evolve and as certain businesses have gained scale. As noted in our previous letters to the Staff, as of December 31, 2023, the Company was organized into the four divisions set forth below, which were then further
broken down into our nine operating segments. Each divisional president reported directly to the CODM and was responsible for overseeing the respective operating segments set forth in the table below.

 2023 Divisional Presidents

 2023 Responsibilities

President, Technology, Shopping & Gaming

Technology, Shopping, Gaming & Entertainment

President, Connectivity

Connectivity

President, Health and Wellness

Health & Wellness Consumer, Health & Wellness Professional, Health & Wellness Pregnancy & Parenting

President, Cybersecurity and Martech

Cybersecurity, Martech

 In 2024, a fifth Divisional President was appointed, and the Tech, Shopping, and Gaming division was divided into two
divisions: 1) Technology & Shopping and 2) Gaming & Entertainment. This was done to create a leadership position (i.e., President) for a promising executive who could bring even greater focus to the Gaming & Entertainment
brands.

 The table below sets forth how the previous nine operating segments listed in the table above under ‘2023 Responsibilities’ align to
the current divisions. These nine operating segments are included in the table below under ‘2024 Responsibilities’. Each divisional president reports directly to the CODM.

 2024 Divisional Presidents

 2024 Responsibilities

President, Technology & Shopping

Technology, Shopping

President, Gaming & Entertainment

Gaming & Entertainment

President, Connectivity

Connectivity

President, Health & Wellness

Health & Wellness Consumer, Health & Wellness Professional, Health & Wellness Pregnancy & Parenting

President, Cybersecurity & Martech

Cybersecurity, Martech

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 FOIA Confidential Treatment Request by

Ziff Davis, Inc. Pursuant to Rule 83 (17 C.F.R. 200.83)

*** - Information omitted and provided under separate cover to the Staff pursuant to Rule 83

 The CODM reviews a monthly reporting package to assess performance and allocate resources [***]. The monthly
reporting package previously provided discrete financial information for our prior nine operating segments. The previous monthly reporting package also provided discrete financial information by the respective divisions outlined above, as well as at
the Company’s prior reportable segment level [***].

 The CODM no longer manages the business based on the previous nine operating segments as
evidenced by the fact that the information he receives to allocate resources and assess performance no longer includes information at the level of the prior nine operating segments. As a result, we have revised our operating segment structure to
align with our divisional structure. In light of this, the monthly reporting package has changed and the CODM no longer receives discrete financial information for our prior nine operating segments. The lowest level of discrete financial information
in the monthly reporting package is the five divisions outlined above, which we have determined to be our operating segments. Further, the CODM does not regularly receive other reports, through the CODM reporting package or otherwise, that include
the performance measures noted above below the divisional level.

 Budgets are prepared for the five divisions, and the divisional presidents are evaluated
based on their respective division’s performance. As it relates to the Company’s 2025 annual budget, each divisional president is in the process of presenting their respective division’s budget to the CODM for review and approval.
These divisional budgets will also be presented to the Company’s Board of Directors in February 2025 for final approval. The CODM does not receive budgets for the performance measures noted above below the divisional level either in his role as
CEO or as a member of the Board of Directors.

 [***]

 The
CODM is a member of the board of directors and therefore also receives the information that the board of directors receives. [***]

 [***] Accordingly, we
have determined that we have five operating segments which align with our five divisions. Resource allocation and performance assessments are now based on the five operating segments described above.

Conclusion

 In accordance with ASC 280-10-50-1, an operating segment 1) engages in business activities from which it may recognize revenues and incur expense, 2) has
operating results that are regularly reviewed by the CODM to make decisions about resource allocation and assess performance, and 3) has discrete financial information available. We believe based on the operating results that are regularly reviewed
by our CODM to make decisions about resource allocation and assess performance, each of the divisions noted above is an operating segment. Thus, the Company’s current operating segments are: (1) Technology & Shopping,
(2) Gaming & Entertainment, (3) Health & Wellness, (4) Connectivity, and (5) Cybersecurity & Martech.

 ZD-03

 FOIA Confidential Treatment Request by

Ziff Davis, Inc. Pursuant to Rule 83 (17 C.F.R. 200.83)

*** - Information omitted and provided under separate cover to the Staff pursuant to Rule 83

 Reportable Segments

The Company expects to report [***] reportable segments in its 2024 Annual Report on Form 10-K as follows [***]. The
Company has evaluated three operating segments [***] for aggregation into a [***] reportable segment as further described below.

 Aggregation of
Operating Segments

 The Company believes that its aggregation analysis with respect to these three operating segments is consistent with the
criteria set forth in ASC 280-10-50-11, which provides that two or more operating segments may be aggregated if aggregation is
consistent with the objectives and principles of ASC 280, if the operating segments have similar economic characteristics, and if the operating segments are similar in the following five qualitative characteristics: (a) the nature of the
products and services, (b) the nature of the production processes, (c) the type or class of customer for their products and services, (d) the methods used to distribute their products or provide their services, (e) and the nature
of the regulatory environment.

 The Company has concluded that because Cybersecurity and Martech are now a single operating segment, they do not need to
be analyzed to determine whether they meet the aggregation criteria as set forth in ASC 280-10-50-11.

Similar Qualitative Characteristics

 The Company
determined that the operating segments are similar in (a) the nature of their products and services, (b) the nature of their production processes, (c) the type or class of customers for their products and services, (d) the
methods used to distribute their products or provide their services, and (e) the nature of the regulatory environment. The Company’s analysis is presented below.

a. The nature of products and services

 Each of the
operating segments [***] publish and produce trusted editorial content and tools for users seeking information and advice. These segments monetize their audiences through a combination of advertising, performance marketing, subscription, and
licensing revenues.

 These businesses publish original and licensed content, research, and tools to generate traffic. Whether monetized through an
advertising and performance marketing model, or a subscription or licensing based model, revenue is primarily earned by generating traffic to the Company’s websites, apps, and third-party platforms on which the Company’s brands have a
presence and then by monetizing this traffic. These sources of revenue include Advertising and Performance Marketing, Subscription and Licensing, and Other as further described below.

Advertising and Performance Marketing - We sell online display and video advertising on our owned-and-operated digital properties and on third-party sites. We have contractual arrangements with advertisers either directly or through advertising agencies. The terms of these contracts specify the
price of the advertising to be sold and the volume of advertisements that will be served over the course of a campaign. Additionally, we have contractual arrangements with certain third-party digital properties not owned by us, and third-party
advertising networks to deliver online display and video advertising to their digital properties or to third-party sites. We generate leads for advertisers, including vendors of consumer health and wellness products, consumer packaged goods, and
information technology services, through various marketing methods. We generate clicks to online merchants by listing products, deals, and discounts on our web properties, and earn a commission when customers “click-through” the ad to make
a purchase.

 Subscription and Licensing - In these three operating segments, we primarily offer subscription and licensing services through
subscription packages to consumers through our weight loss app and through our digital subscription and storefront for video games, ebooks, and software.

 ZD-04

 FOIA Confidential Treatment Request by

Ziff Davis, Inc. Pursuant to Rule 83 (17 C.F.R. 200.83)

*** - Information omitted and provided under separate cover to the Staff pursuant to Rule 83

 Other - Other revenues primarily include online course revenue and game publishing revenue.

Below is a breakdown of advertising and performance marketing revenue and subscription and licensing revenue for each operating segment as of
September 30, 2024.

 For the nine months ended September 30, 2024

Advertising and
Performance
Marketing

Subscription and
Licensing

Other

 [***]

[***]

[***]

[***]

 [***]

[***]

[***]

[***]

 [***]

[***]

[***]

[***]

 Further, information regarding the breakdown of subscription and licensing revenue by type and by operating segment as a
percentage of subscription and licensing revenue for the year ended December 31, 2023 is shown in the table below.

Percent of Subscription and Licensing Revenue for Three
Aggregated Operating Segments

For the year ended December 31, 2023(1)

[***]

[***]

[***]

 Subscriptions to websites or apps

[***]

[***]

[***]

 Intellectual property licenses

[***]

[***]

[***]

 Other

[***]

[***]

[***]

 Total

[***]

[***]

[***]

[***]

 Our operating segments have a mix of
advertising and performance marketing revenue and subscription and licensing revenue. The revenue transactions across these operating segments are primarily generated directly with clients and through agency intermediaries. The nature of services
provided by these operating segments are similar to each other in that they monetize internet traffic on various platforms by providing content to consumers and businesses. Each of these operating segments has editorial organizations that create
authoritative content to generate traffic to a website, internet video content, a social media platform, or through an app. The content is in the form of information or entertainment related to the various verticals in which we operate. Traffic is
monetized in numerous ways and primarily includes the following: Advertising revenue from banner ads, commission revenue when customers “click through” the ad to make a purchase, and subscriptions to
end-customers that consume and or otherwise use exclusive content.

 The operating segments each operate sales
teams to present or respond, in the case of requests for proposals (RF