SecProbe.io

April 24, 2012
 Via E-Mail

Ms. Kathy Willard Chief Financial Officer Live Nation Entertainment, Inc. 9348 Civic Center Drive  Beverly Hills, California 90210
Re: Live Nation Entertainment, Inc.
 Form 10-K for the Year Ended December 31, 2011
Filed February 24, 2012 File No. 001-32601

Dear Ms. Willard:
 We have reviewed your filing 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 this letter within 10 bus iness days by confirming that you will revise
your document in future filings and providing an y requested information.  If you do not believe
our comments apply to your facts and circumst ances, please tell us why in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.

Form 10-K for the Year Ended December 31, 2011

 Management’s Discussion & Analysis

Critical Accounting Policies and Estimates, page 73
Income Taxes, page 76

1. We note your disclosure that because a ll earnings from your continuing foreign
operations are permanently reinvested and not distributed, your income tax provision
does not include additional United States taxe s on those foreign operations.  Please revise
your liquidity section of MD&A to disc lose the amount of cash and short term
investments held by foreign subsidiaries; a statement that the company would need to
accrue and pay taxes if repatriated; and a st atement that the company does not intend to
repatriate the funds.  Also, in light of the significant reconciling item due to differences
of  foreign taxes from U.S. st atutory taxes in the statutory ta x rate reconciliation disclosed
in Note 10, please identify for us the countries  for which this reconciling item relates.
Finally, please revise Note 10 to disclose th e cumulative amount of earnings of foreign

Ms. Kathy Willard Live Nation Entertainment, Inc. April 24, 2012 Page 2

 subsidiaries in which U.S. income taxes have not been provided because they are
considered to be permanently reinvested.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Claire Erla nger at (202) 551-3301 or Jean  Yu at (202) 551-3305 if you
have questions regarding comments on the financ ial statements and related matters.  You may
also contact me at (202) 551-3813.
Sincerely,
   /s/ Linda Cvrkel    Linda Cvrkel
Branch Chief