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Correspondence

 [Live Nation Logo]

 2000 West Loop South, Suite 1300

 Houston, TX 77027

 February 24, 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 September 30, 2008

Filed November 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 January 28, 2009 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
September 30, 2008 (the “2008 Third Quarter Form 10-Q”). 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.

 Confidential treatment requested by Live Nation, Inc. for

 portions of this letter in accordance with 17 C.F.R. § 200.83

 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,

 /s/ Brian J. Capo

 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

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 Confidential treatment requested by Live Nation, Inc. for

 portions of this letter in accordance with 17 C.F.R. § 200.83

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

 Loss (gain) on sale of operating assets, page 55

 Consolidated and Combined Statements of Operations, page 85

 Comment 1: We note from the discussion in the MD&A
and from your consolidated statements of operations for 2007 and 2006 that the Company recognized a significant level of gains from the sale of operating assets during these periods. Please tell us the nature and significant terms of the
transactions that resulted in the significant level of gains on disposals of assets during 2007 and 2006. Also, please revise the notes to your financial statements to include all of the disclosures outlined in paragraph 47 of SFAS No. 144 with
respect to any long-lived assets sold during the periods presented in your financial statements. Furthermore, please explain why the results of operations for the entities or assets disposed of have not been reflected as discontinued operations in
your financial statements pursuant to the guidance in paragraphs 41 through 44 of SFAS No. 144. We may have further comment upon receipt of your response.

 Response: During 2007 and 2006, the Company sold a number of operating assets. The assets sold were listed in Note 15 – Other Information of the 2007 Form 10-K. As a point of reference for the disposal transactions listed
in the next section, some background related to the components impacted by the disposals follows:

•

 The live music division is managed centrally within the United States as well as centrally for international locations. The booking of talent is performed by a
regional team of promoters and the venues are used interchangeably. If one venue in a region is sold, the artists are rerouted to another venue in that region. The management of these regional live music divisions, which include promotion and venue
management, is therefore very integrated and centralized. As a result, the Company considers each regional live music division to be a component.

•

 The theatrical business was managed in three divisions: Broadway Across America, the theatrical venue management business and the theatrical production business.
The Broadway Across America division was a presentation business for third-party theatrical touring companies. The Company’s activities included securing venues, advertising the shows and selling the tickets for mainstream theatrical
productions. The theatrical venue management business consisted primarily of renting theatrical venues to third-party theatrical productions. The theatrical production business consisted of developing the production content, building the sets,
hiring musicians and talent as well as other activities necessary to develop and produce shows for a theater setting, but not of a mainstream theatrical nature. Most assets in this division consisted of rights to productions under development that
did not reach the production stage before they were disposed of, therefore the division historically did not produce significant earnings. The Company considers these three divisions to be separate components.

•

 The Company’s motor sports business included promoters of specialized motor sports events. Typical events included motorcycle road racing, supercross racing,
monster truck shows, freestyle motocross events and other similar events. The motor sports business is managed as one division, but conducted business in the United States, Canada, the United Kingdom and other countries. The Company views the motor
sports business as one component.

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 Confidential treatment requested by Live Nation, Inc. for

 portions of this letter in accordance with 17 C.F.R. § 200.83

•

 The sports representation business consisted of sports marketing and management for basketball, golf, football, media, tennis, baseball, soccer and rugby talent.
The Company managed this division centrally and views this business as one component. Additionally, some of the agents worked in more than one of these areas. The sports representation business has historically not been significant to the Company.

 Additionally, subsequent to the Company’s separation from Clear Channel Communications, Inc. (“Clear Channel”), the
Company concluded that its core operations consisted of the live music business. As a result, portions of components (although not necessarily entire components) were subsequently sold in 2006 and 2007.

 Specifically, the nature and significant terms of the disposal transactions during 2007 and 2006 are as follows, together with an explanation of why each disposal did
not result in a discontinued operations presentation as prescribed by SFAS No. 144 and EITF 03-13:

 2007

•

 During the first quarter of 2007, the Company sold Donington Park, a venue in Leicestershire, England that served as a race track and a music arena that held a
large annual music festival. The Company sold this asset as the management of the race track business was not part of the core operations of the Company; however, the Company continued to hold its annual festival at the venue after the sale and
conduct other motor sports business in the United Kingdom. As the Company continued to have significant cash flows in the motor sports component and there would be continued cash flows from the disposed asset, it did not qualify for presentation as
discontinued operations. The majority of the purchase price was paid in cash with the remainder payable in three annual installments and the gain was $3.6 million. There were no contingent payment terms as part of this transaction.

•

 During the first quarter of 2007, the Company sold its remaining 50.1% interest in the production of Phantom: The Las Vegas Spectacular. Although this was a
recent investment contained in the theatrical productions division of the Theatrical business, this asset was sold because it was not profitable and was determined to be non-core to the Company. This asset was not presented as discontinued
operations due primarily to lack of materiality to the Company’s financial statements, as it ended up being a very short-term investment with less relevance to the Company’s principal operations and produced operating losses of $1.8
million in 2006 and $2.4 million in 2007, excluding the loss on sale. The purchase price was paid in cash and the loss incurred was $8.1 million. This asset was sold to former members of the Company’s management and there was a contingent
payment clause in the sale agreement, for which no consideration has been received to date by the Company. There were no deferred payment terms as part of this transaction.

•

 During the second quarter of 2007, the Company sold the Starwood Amphitheater located in Nashville, Tennessee due to poor financial performance. As the Company
continued to have significant cash flows in the regional live music component, it did not qualify for presentation as discontinued operations. The purchase price was paid in cash and the gain was $0.5 million. There were no deferred or contingent
payment terms as part of this transaction.

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 Confidential treatment requested by Live Nation, Inc. for

 portions of this letter in accordance with 17 C.F.R. § 200.83

•

 During the second quarter of 2007, the Company sold an office building it acquired as part of the purchase of Bill Graham Presents in 1998. The building was used as
office space for some of the Company’s operations personnel. Due to significant increases in real estate values in the region in which it was located, the Company sold the building. The purchase price was paid in cash and resulted in a gain of
$6.0 million. As this asset was not a revenue producing asset for a component of the Company, it did not qualify for discontinued operations presentation.

•

 During the second quarter of 2007, the Company sold the Hammersmith Apollo music venue in London, England as required by The Competition Commission as a condition
to allowing the Company’s acquisition of 55.9% of Academy Music Holdings, Limited. As the Company continued to have significant cash flows in the United Kingdom live music component, it did not qualify for presentation as discontinued
operations. The purchase price was paid in cash and the gain was $12.3 million. There were no deferred or contingent payment terms as part of this transaction.

•

 During the second quarter of 2007, the Company sold the Forum music venue in London, England as required by The Competition Commission as a condition to allowing
the Company’s acquisition of 55.9% of Academy Music Holdings, Limited. As the Company continued to have significant cash flows in the United Kingdom live music component, it did not qualify for presentation as discontinued operations. The
purchase price was paid in cash and the gain was $0.6 million. There were no deferred or contingent payment terms as part of this transaction.

•

 During the third quarter of 2007, the Company sold seven music clubs located in London that had been acquired as part of the Mean Fiddler acquisition in 2005. As
part of the sale of the Hammersmith Apollo and Forum assets as discussed above, the Company gave the buyer of Hammersmith Apollo and Forum the option to purchase these venues at a later date, which was subsequently exercised. The Company decided to
sell the clubs, some of which had been closed down, because all were small establishments that did not produce material earnings. As the Company continued to have significant cash flows in the United Kingdom live music component, it did not qualify
for presentation as discontinued operations. The purchase price was paid in cash and the gain was $5.8 million. There were no deferred or contingent payment terms as part of this transaction.

•

 During the fourth quarter of 2007, the Company sold the Oriental Theatre in Chicago and the Company’s 50% interest in Broadway in Chicago. The Company sold
these assets as the Theatrical division was determined to not be part of the core operations of the Company. These assets were originally part of a larger package of theatrical assets being offered for sale, the other portion of which was sold in
2008. These assets were sold separately as the owners of the remaining 50% interest had a right of first refusal and desired to purchase the Oriental Theatre and the interest in Broadway in Chicago. The assets sold in this transaction were part of
the Broadway Across America component which had significant continuing cash flows

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 Confidential treatment requested by Live Nation, Inc. for

 portions of this letter in accordance with 17 C.F.R. § 200.83

and, therefore, did not qualify for discontinued operations presentation. In addition, Broadway in Chicago represented an equity method investment, and
equity method investments are not considered separate components (as clarified by the FASB at its November 14, 2001 board meeting). The remaining portion of this component was sold in 2008 and the Company is reflecting this component as
discontinued operations in the Form 10-K for the year ended December 31, 2008 (the “2008 Form 10-K”) as it had no continuing involvement with the buyer and had no intention of entering back into the theatrical presentation business in
the future. The purchase price was paid in cash and the gain was $31.3 million. There were no deferred or contingent payment terms as part of this transaction.

•

 The remaining transactions included in the net gain for 2007 were smaller transactions such as the sales of property, plant and equipment and a small venue, all of
which were sold for cash at a net loss of $0.8 million. None of these assets comprised a component and therefore did not qualify for discontinued operations presentation.

 2006

•

 Throughout 2006, the Company sold various portions of its sports representation business as it was determined not to be core to the Company’s operations.
However, the Company continued to have an existing sports business at the time of the completion of these transactions. Additionally, complete, discrete financial information did not exist for each of these sports businesses sold. For these reasons,
the sold assets did not constitute a component or components, but were part of the larger sports representation business component which continued to have significant cash flows, and therefore the sold assets did not qualify for discontinued
operations presentation. All of the purchase prices were pai