SecProbe.io

Mail Stop 3561
        June 7, 2011  Via Fax & U.S. Mail

 Ms. Kathy Willard Chief Financial Officer 9348 Civic Center Drive Beverly Hills, California 90210

Re: Live Nation Entertainment, Inc.
 Form 10-K for the fiscal year ended December 31, 2010
Filed February 28, 2011
  File No. 001-32611
Dear Ms. Willard:

We have reviewed your response letter  dated May 27, 2011 and have the following
comments.  Unless otherwise indicated, we th ink you should revise your document in future
filings in response to these comments.  If you disa gree, we will consider y our explanation as to
why our comment is inapplicable or a revision is  unnecessary.  Please be as  detailed as necessary
in your explanation.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.  Af ter reviewing this information, we may raise
additional comments.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filing.  We look forward to working with you in these respects.  We welcome any questions
you may have about our comments or any other aspect of our review.  Feel fr ee to call us at the
telephone numbers listed at the end of th is letter.

Please respond to confirm that such comments will be complied with, or, if certain of the
comments are deemed inappropriate, advise the staff of your reason.  Your response should be
submitted in electronic form, under the label “corres p” with a copy to the staff.  Please respond
within ten (10) business days.
Form 10-K for the Year Ended December 31, 2010

Notes to the Financial Statements
 Note 19. Quarterly Results of Operations, page 130

Ms. Kathy Willard Live Nation Entertainment, Inc. June 7, 2011 Page 2

1. We note from your response to our prior co mment 14 and revise disclosure that the
settlement of a pre-existing relationship with LN-Haymon resulted in a gain of $6.1
million.  Please provide us more detail as to how this gain was calculated or determined.
As part of your response, please tell us how you followe d the guidance in ASC 805-10-
55-21 in calculating the gain recognized.
 Form 10-Q for the quarter ended March 31, 2011

 Note 3. Acquisitions – Front Line

2. We note from your disclosure that in connect ion with the purchase of Front Line stock,
you issued shares of Live Nation common stock to the Azoff Sellers and to MSG.   Please
explain to us, and disclose in the notes to future filings, how you determined or calculated
the value of the shares issued.  Also, please revise the cash flow statement in future
filings to disclose this issuance of common shares as a non-cash investing or financing
activity.

3. We note from your disclosure in Note 3 that as a result of the re purchases, you recorded
$24.4 million in selling, general and administrativ e expenses in the first quarter of 2011.
Please explain to us in detail, how you determined or calculated the $24.4 million
amount.

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  You may contact Claire Erlange r at (202)551-3301 or Jean Yu  at (202)551-3305 if you have
questions regarding comments on the financial statem ents and related matters.   Please contact me
at (202) 551-3813 if you have any other questions.
Sincerely,

Linda Cvrkel Branch Chief
   Via facsimile (310) 867-7054