SecProbe.io

May 12, 2015

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, 2014
Response Dated April 21, 2015
File No. 001 -32601

Dear Ms. Willard :

We have reviewed  your April 21, 2015 response to our comment letter 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 r espond to these comments  within ten business days by  providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have additional comments.
Unless we note otherwise, our references to prior comments are to comments in our April 7,
2015 letter .

Form 10 -K for the Year Ended December 31, 2014

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Consolidated Results of Operations, page 30

1. We note from your response to our prior comment 1 that in determining which key
metrics to disclose in the 2014 10 -K, management considered those metrics that most
impact the Concerts and Ticketing businesses and have the most direct impact on overall
fluctuations in revenue.  However, in light of the fact that it appears different venues have
different impacts on revenue in the Concerts segment, we would expect to see metrics
that reflect the differences in these venues (e.g. stadium events vs. arena events).  Also,
we note that that operating m etrics relating to secondary ticket sales are not included in
your Form 10 -K.  In light of the fact that it appears the increased revenue from your
secondary ticket sales business had a significant effect on revenue in the Ticketing

Kathy Willard
Live Nation Entertainment, Inc.
May 12, 2015
Page 2

 segment for 2014, pleas e consider including metrics related to these sales (such as
secondary ticket volume) in your MD&A discussion.  Please revise accordingly.

Consolidated Results of Operations, page 30

2. We note your response to our prior comment 2 and continue to have fur ther questions
regarding your income tax disclosure.  Please provide us the following information:
 Provide us your pre -tax income/loss, statutory tax rate, and tax expense/benefit by
jurisdiction;
 For each jurisdiction where the tax expense/benefit differs  from the pre -tax
income/loss multiplied by the statutory rate, please explain to us the nature of the
differences;
 Please explain to us how the $1 0,735 reconciling item titled “differences between
foreign and United States statutory rates” was calculated or determined; and
 Explain to us why your provision for income taxes includes foreign tax expense
(rather than a tax benefit) considering you had a net foreign loss before taxes of $83.6
million.

You may contact  Claire Erlanger  at (202) 551 -3301 or me at (202) 551 -3379  with any
questions.

Sincerely,

 /s/ Melissa Raminpour

 Melissa Raminpour
Branch Chief