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Response Letter

 [ON LIVE NATION LETTER HEAD]

 December 11, 2008

 Via EDGAR and Facsimile

 United States Securities and Exchange Commission

 100 F Street, N.E.

 Washington, DC 20549

Attention:

Ms. Linda Cvrkel

Ms. Heather Clark

Re:

Live Nation, Inc.

Form 10-K for the year ended December 31, 2007

Filed February 29, 2008

Form 10-Q for the quarter ended June 30, 2008

Filed August 7, 2008

File No. 001-32601

 Ms. Cvrkel and Ms. Clark:

 Set forth below are the responses of Live Nation, Inc. (“Live Nation” or the “Company”) to the comments of the staff of the Securities and Exchange Commission (the “Staff”) contained in
your letter dated November 13, 2008 with respect to the Form 10-K for the year ended December 31, 2007 (the “2007 Form 10-K”) and the Form 10-Q for the quarter ended June 30, 2008. For your convenience, the comments provided
by the Staff have been included in the order presented in the comment letter, immediately followed by Live Nation’s responses. Along with its EDGAR-filed copy, Live Nation is concurrently transmitting via facsimile a courtesy hard copy of its
response to the Commission.

 In some of Live Nation’s responses, the Company has agreed to change or supplement the disclosures in its filings. The
Company is doing that in the spirit of cooperation with the Staff, and not because the Company believes that its prior filings are materially deficient or inaccurate. Accordingly, any changes implemented in future filings should not be taken as an
admission that prior disclosures were in any way deficient.

 Live Nation also has indicated in a number of its responses that it believes no change in
disclosure is appropriate, and has explained why. The Company understands the Staff’s comments, even where a disclosure change is requested or suggested, to be based on the Staff’s understanding based on information available to it, which
may be less than the information available to Live Nation. As such, the Company seeks to supply the Staff with additional explanations or information in order to allow the Staff to have the details needed to potentially withdraw or modify its
comments as appropriate.

 Per your request, the Company acknowledges the following:

•

 Live Nation is responsible for the adequacy and accuracy of the disclosure in the filings;

•

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

•

 Live Nation 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.

 The Company hopes that this letter is helpful and responsive to your requests. If you have any questions or comments to these
responses, please do not hesitate to contact me directly at (713) 693-2626.

 Very truly yours,

 Brian J. Capo

 Senior Vice President and Chief Accounting Officer

cc:

Michael Rapino, President and Chief Executive Officer

Kathy Willard, Executive Vice President and Chief Financial Officer

Michael Rowles, Executive Vice President and General Counsel

 -2-

 Annual Report on Form 10-K for the year ended December 31, 2007

 Available Information, page 24

 Comment 1:
Please revise future filings to reflect the correct SEC mailing address of 100 F Street NE.

 Response: The Company will correct the
address for all future filings.

 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 48

 Selling, general and administrative expenses, page 54

 Comment 2: We note from the discussion on page 55 that the company’s selling, general and administrative expenses decreased by $7.0 million during 2006 as a result of pre-acquisition contingencies
for legal matters that were resolved during the period. Please tell us the specific acquisition to which this pre-acquisition contingency relates, the date that this acquisition transaction occurred, and the date that the legal matters were
subsequently resolved. We may have further comment upon receipt of your response.

 Response: The $7.0 million relates to litigation, or
potential litigation, contingency accruals recorded in accordance with SFAS 5 on the Company’s books as part of purchase accounting for the acquisition of SFX Entertainment, Inc. by Clear Channel Communications, Inc. (“Clear Channel”)
in August of 2000. The decrease relates primarily to three accruals totaling $6.7 million. One of these accruals for $0.5 million was released in the first quarter of 2006 when final settlement amounts were known for the case. The remaining two
accruals were released in the fourth quarter of 2006. One accrual for $3.9 million was released as a result of the positive conclusion in court during October 2006 of the remaining appeals related to the case. The other amount of $2.3 million was
the excess accrual above the final judgment in an unrelated case that was ruled on by the courts in the fourth quarter of 2006. The remaining overall decrease, totaling $0.3 million, relates to accruals that were not material individually or in the
aggregate and for which the Company determined in 2006 that a contingency no longer existed.

 Financial Statements, page 83

 Notes to Consolidated and Combined Financial Statements, page 88

 Note 1 – Summary of Significant Accounting Policies, page 88

 Subsequent to Separation, page 88

 Comment 3: We note the disclosure on page 89 indicating that during 2006, the company recorded an additional adjustment to paid-in capital of $10
million to adjust the carrying value of assets distributed at the date of spin-off. Please explain in further detail the facts and circumstances that resulted in this additional adjustment during 2006 and explain how it was calculated or determined.

 Response: As discussed in the 2007 Form 10-K, the Company separated from Clear Channel on December 21, 2005. As part of that
separation, Clear Channel provided to the Company its deferred tax position for the establishment of its separate financial statements. Subsequent to the separation, during 2006, the Company continued to assess the categorization of the deferred tax
amounts provided by Clear Channel as well as the assignment between Clear Channel and the Company. As a result of that review, the Company

 -3-

determined that a deferred tax asset of $10 million was incorrectly allocated to the Company because it was associated with an asset retained by Clear
Channel. The deferred tax asset was removed with the offset to additional paid-in capital as this correction represented a change in the book basis of the shareholders’ equity at separation date.

 Revenue Recognition, page 92

 Comment 4:
We note from the business section that the company earns revenue from multiple types of transactions including events, ticket sales, food and beverage revenues, rental revenues, venue sponsorships, and merchandise sales. To the extent
significant, please revise your accounting policy footnote in future filings to clarify your revenue recognition policies with regards to all types of revenue, addressing when the criteria of SAB 104 has been met for each revenue type.

Response: The Company believes its revenue recognition disclosure currently includes all significant revenue types as the revenues related to the
presentation and production of events presently disclosed in the accounting policy footnote accounted for 89%-91% of its 2005-2007 revenues and these revenue types are all accounted for in a consistent manner after the performance occurs. This event
revenue includes categories such as ticketing-related revenue, day of show revenue (such as event concession and merchandise fees) and revenue from the sale to third parties of the right to promote specific events. The Company also discloses its
accounting policy for sponsorship and membership revenues representing 3%-4% of its 2005-2007 revenues, thereby disclosing in total its accounting policy for 93%-94% of its revenues for the three years. The remaining 6%-7% of revenue is accounted
for in accordance with SAB 104, and the Company believes specific disclosure is not required as it is not material to the Company. Please see the table below displaying the Company’s revenue types and amounts for the relevant years.

2007

2006

2005

($ millions)

 Event-Related Revenue

$
3,736

89
%

$
3,365

91
%

$
2,623

89
%

 Sponsorship & Membership Revenue

165

4
%

113

3
%

121

4
%

 Non-Event Revenue

284

7
%

234

6
%

193

7
%

 Total Company Revenue

$
4,185

100
%

$
3,712

100
%

$
2,937

100
%

 Comment 5: In a related matter, to the extent material amounts of revenue are recognized from the
sale of products (food, beverage, merchandise) and from the provision of services (events, etc.) and rental revenues, please revise your consolidated and combined statements of operations in future filings to provide separate disclosure of revenues
from sales of products, from rental revenues and from the provision of services. Separate disclosure of the related costs of sales should also be provided for the costs associated with each of these activities. Refer to the guidance outlined in Rule
5-03(b)(l) and (2) of Regulation S-X.

 Response: The Company believes that it does not have a significant amount of product revenue that
would require separate disclosure on the face of the consolidated and combined statements of operations. As noted in the table below, the Company’s product revenue averages only 3% of total revenue per year. These product revenues are comprised
of merchandise and restaurant revenue that are not

 -4-

associated with events. In addition, the Company outsources event-related concession sales, whereby the Company only receives a fee or percentage of the
revenue and does not purchase or take title to any of the inventory sold. As such there is no related cost of goods sold. Event merchandise is sold by the artists and the Company only receives a fee. The Company considers these event-related
concession and merchandise revenue streams to be service revenue as it does not participate directly in these transactions. Rental revenue represents only 2% of total revenues and consists of venue rentals to third parties for specific shows (the
Company categorizes this revenue as event-related).

 If income is derived from more than one sub caption required under Rule 5-03(b)1, Rule 5-03(b) allows
for the combination, into another class, of each revenue class which is not more than ten percent of the sum of all revenues as well as requires similar treatment for the corresponding costs and expenses. Based upon the small amount of product and
rental revenue, the Company does not believe that additional disclosure of revenue is required on the consolidated and combined statements of operations.

2007

2006

2005

($ millions)

 Total Product Revenue

$
126

3
%

$
117

3
%

$
84

3
%

 Total Rental Revenue

104

2
%

92

3
%

81

3
%

 Total Service Revenue:

 Event-Related Service Revenue

3,632

87
%

3,273

88
%

2,542

86
%

 Non-Event Service Revenue

323

8
%

230

6
%

230

8
%

 Total Service Revenue

3,955

95
%

3,503

94
%

2,772

94
%

 Total Company Revenue

$
4,185

100
%

$
3,712

100
%

$
2,937

100
%

 Note 2 – Long-Lived Assets, page 95

 Goodwill, page 97

 Comment 6: We note from
the disclosure in Note 2 that the company reorganized its operating segments in 2007 and as a result, goodwill has been reallocated to the new reporting business units that make up these segments utilizing a fair value approach. Please tell us and
revise Note 2 to explain in further detail the nature of the “fair value approach” used and the nature and amounts of the adjustments to goodwill of each of your segments that resulted from this reallocation process. Refer to the
disclosure requirements outlined in paragraph 45 of SFAS No.142.

 Response: When reallocating goodwill to the new reporting units, the
Company looked to paragraph 36 and 39 of SFAS 142 which requires that the allocation be “based on the relative fair values similar to that used when a portion of a reporting unit is being disposed of.” The Company believes a common method
used to determine the fair value of a business in its industry is a multiple of projected earnings before interest, taxes, depreciation and amortization.

 -5-

Beginning with the first year-end prior to separation date, or December 31, 2004, the Company reallocated the goodwill assigned to it by Clear Channel
at separation using each reporting unit’s relative fair value as calculated by the respective reporting unit’s percentage of total Company projected earnings before interest, taxes, depreciation and amortization, excluding Corporate and
reporting units that had a fair value less than zero. For purposes of the calculation, the multiple of earnings before interest, taxes, depreciation and amortization was constant for all reporting units. Goodwill related to specific acquisitions
subsequent to December 31, 2004 was attributed to the respective new reporting units directly (specific allocation). This methodology appeared to be most appropriate to the Company as the goodwill related to these subsequent acquisitions was
specifically identifiable to the new reporting units. Please see the table below for detail of the allocations from the old reportable segments to the new reportable segments. Acquisitions, Foreign currency and Adjustments amounts for the 2006
Segments presentation in the table below are the same as those disclosed and discussed in the footnotes to the Form 10-K for the year ended December 31, 2006. Please note the 2006 recast amounts resulting from the fair value approach are
negative because the amounts being allocated under this approach are principally the Adjustments category which is negative for all segments and in total. The Adjustments primarily represent acquisition-related tax impacts occurring after the
twelve-month allocation period that require adjustment to goodwill. The remaining amounts to allocate in 2005 are generally current year acquisitions specifically identifiable to the new reporting units.

2006 SEGMENTS

2007 SEGMENTS

Total

Events

Venues and
Sponsorship

Digital
Distribution

North
American
Music

International
Music

Global
Artists

Global
Digital

Global
Theater

($ thousands)

 Balance as of 12/31/04:

$
10,618

$
 24,899

$
 9,296

$
 —

$
 —

$
 —

$
 —

$
 —

$
 44,813

 Acquisitions

72,209

33,397

1,550

107,156

 Foreign currency

(420
)

(985
)

(368
)

(1,773
)

 Adjustments

(3,100
)

(7,271
)

(2,715
)

(13,086
)

 Recast balances

 Fair value approach

(8,867
)

(20,793
)

(7,763
)

14,349

14,542

3,297

—

5,235

—

 Specific allocation

(70,440
)

(29,247
)

5,767

93,920

—

—

—

—

 Balance as of 12/31/05:

—

—

—

20,116

108,462

3,297

—

5,235

137,110

 Acquisitions

6,080

282,499

11,138

299,717

 Foreign currency

1,470

3,446

1,287

6,203

 Adjustments

(4,706
)

(11,035
)

(4,120
)

(19,861
)

 Recast balances

 Fair value approach

3,188

7,476

2,791

(5,159
)

(5,228
)

(1,186
)

—

(1,882
)

—

 Specific allocation

(6,032
)

(282,386
)

(11,096
)

276,096

10,336

11,100

—

1,982

—

 Balance as of 12/31/06:

$
—

$
—

$
—

$
291,053

$
113,570

$
13,211

$
—

$
5,335

$
423,169

 The Company did review the requirement under paragraph 45 to “disclose any significant changes in the
allocation of goodwill by reportable segment.” The Company did not interpret the guidance to mean this required disclosure of dollar amounts, but disclosure of the changes that would be meaningful information. The Company believes that since
there was such a substantial change in the nature of the reportable segments, a numerical reconciliation of goodwill from old to new reportable segments would not have provided meaningful information. The Company believes it was in compliance with
the requirements of paragrap