SecProbe.io

April 28, 2016

Via Email
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 Fiscal  Year Ended December 31, 2015
Filed February 25, 2016
File No. 001 -32601

Dear Ms. Willard :

We have limited our review  of your filing  to the financial statements and related
disclosures 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you wil l 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.

Form 10 -K for Fiscal  Year Ended December 31, 201 5

Note 1. The Company and Summary of Significant Accounting Policies

Non-Cash and Stock -based Compensation, page 64

1. We note your disclosure in Note 1 that you use the simplified method for estimating the
expected life within the valuation mod el because you do not believe historical experience
provides a reasonable basis with which to estimate the expected term due to the impact of
a number of divestitures after the Separation, the varying vesting terms of awards issued
since the Separation and  the impact from the type and amount of awards converted
pursuant to the Company’s merger with Ticketmaster.  In light of the fact that the
Separation referred to was over ten years ago and the Ticketmaster acquisition was in
2010, please explain to us why  you believe it is appropriate to continue using the
simplified method in your valuation of stock options.

Kathy Willard
Live Nation Entertainment, Inc.
April 28, 2016
Page 2

 Note 2. Long -Lived Assets

Investments in Nonconsolidated Affiliates, page 71

2. We note your disclosure on page 71 that among other investments, for the year ended
December 31, 2015, your 60% investment in Vice Nation, LLC was significant on an
individual basis.  Please explain to us why you believe it is appropriate to account for this
investment using the equity method of accounting, considering your 60% ownership in
the entity.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchan ge Act rules require.   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 provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commissi on 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 federal securities laws of the United States.

You may contact Kristin S hifflett at 202 -551-3381, Claire Erlanger at 202 -551-3301  or
me at 202-551-3377  with any questions.

Sincerely,

 /s/ Lyn Shenk for

 Andrew Mew
Senior Assistant Chief Accountant