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Response Letter

 [Letterhead of Live Nation Entertainment, Inc.]

May 27, 2011

 Via EDGAR and
Facsimile

 United States Securities and Exchange Commission

 100 F Street, N.E.

 Washington, DC 20549

Attention:
Ms. Linda Cvrkel

Ms. Claire Erlanger

Re:
Live Nation Entertainment, Inc.

Form 10-K for the year ended December 31, 2010

Filed February 28, 2011

File No. 001-32601

 Ms. Cvrkel
and Ms. Erlanger:

 Set forth below are the responses of Live Nation Entertainment, 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 April 29, 2011 with respect to the Company’s Form 10-K for the year ended December 31,
2010 (the “2010 Form 10-K”). 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 future 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 certain 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 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

•

 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

 - 2 -

 Form 10-K for the Year Ended December 31, 2010

Management’s Discussion and Analysis

 - Concerts Results of Operations, page 57

 Comment 1: We note from your
disclosure on page 57 that revenue increased during 2010 due to several acquisitions made in 2009. Please tell us why you have not included the disclosures required by ASC 805 in the notes to the financial statements for these 2009 acquisitions. If
the acquisitions were not material either individually or in the aggregate, please state that conclusion.

 Response: The Company
believes that it is in compliance with the disclosure requirements contained in ASC 805 with respect to the 2010 Form 10-K. The disclosure requirements in ASC 805 are limited to material business combinations or individually immaterial business
combinations that are material in the aggregate. The Company does not believe it had any business combinations during 2009 that were material individually or in the aggregate. Acquisitions during 2009 accounted for as a business combination were
comprised of an interest in Brand New Live B.V., an interest in Tecjet Limited, an interest in Parcolimpico S.R.L. and certain assets related to the Pleasure PAAS Party and Pleasure magazine. The Company’s aggregate investment in acquisitions
during 2009 was $7.2 million, the aggregate total assets acquired were $15.4 million and the aggregate loss before income taxes was $5.2 million for the respective most recent full fiscal year. The acquisitions were not considered material
individually, or in the aggregate, using the guidance provided in Regulation S-X Rule 3-05. We will revise future filings to state this conclusion.

 Uses of Cash

 - Capital Expenditures, page 68

Comment 2: Please revise to disclose the estimated amount of capital expenditures the Company expects to incur during the year ended
December 31, 2010. See item 303(A)(2) of Regulation S-K.

 Response: Historically, when the Company has filed its Form 10-Ks, it
has been in the process of finalizing its annual budgets and has refrained from disclosing an estimate for the upcoming year’s capital expenditures in these annual filings as the amounts are not approved by management or the board of directors
and could be subject to significant change. In its March 31, 2011 Form 10-Q, consistent with past practice, the Company has disclosed its estimated capital expenditures for the full year. However, the Company agrees that this is important
information for the readers of its annual filings and will endeavor to finalize its capital expenditures budget prior to the filing of its Form 10-K in future years such that it can include this forward-looking disclosure in its future filings.

 - 3 -

 Audited Financial Statements for the Year Ended December 31, 2010

Statement of Cash Flows, page 81

Comment 3: We note that you have presented the “loss (gain) on sale of operating assets” as a reconciling item in the net cash provided
by (used in) operating activities. Please explain to us why the amounts of this line item do not agree with those on the statement of operations under the “loss (gain) on sale of operating assets” line item for the years ended
December 31, 2010, 2009 and 2008.

 Response: The “loss (gain) on sale of operating assets” reflected as a reconciling
item in the net cash provided by (used in) operating activities on the Consolidated Statements of Cash Flows includes gains and losses from both continuing and discontinued operations. The Company elected not to recast its Consolidated Statements of
Cash Flows for discontinued operations as permitted under ASC 230-10-45-24. The amounts of loss (gain) on sale of operating assets and loss (gain) on disposal attributable to discontinued operations have been disclosed in Note 5 in the 2010 Form
10-K. A reconciliation of the “loss (gain) on sale of operating assets” between the Consolidated Statements of Operations and Consolidated Statements of Cash Flows for the years ended December 31, 2010, 2009 and 2008 is as follows (in
thousands):

2010

2009

2008

 As reported on Consolidated Statements of Cash Flows

$
4,602

$
(64,237
)

$
(165,448
)

 As reported on Consolidated Statements of Operations

374

(2,983
)

1,131

 Variance

$
4,228

$
(61,254
)

$
(166,579
)

 Included in income (loss) from discontinued operations as a component of:

 Gain on sale of operating assets

$
—

$
(6,659
)

$
(2,216
)

 Loss (gain) on disposal, net of tax

4,228

(54,595
)

(99,777
)

 Tax component of loss (gain) on disposal

—

—

(64,586
)

 Total Variance Explained

$
4,228

$
(61,254
)

$
(166,579
)

 Comment 4: We note from the statement of cash flows that you made payments for deferred and contingent consideration
in both 2010 and 2009. Please tell us, and disclose in the notes to the financial statements in future filings, the nature of these payments and explain to us how you accounted for these payments in your financial statements.

Response: The payments included on that line in the Consolidated Statements of Cash Flows included both payments related to contingent
consideration and also payments for deferred purchase liabilities in both years. The Company has certain contingent consideration obligations related to acquisitions of several artist management companies and a concert promotion company that were
made after the adoption in January 2009 of the FASB guidance for business combinations. The amounts due to the sellers of those companies are based on the achievement

 - 4 -

of agreed-upon financial performance metrics by the acquired companies. The Company records the estimated fair value of the liability at the time of the acquisition based on management’s
best estimate of the future results of the acquired companies as compared to the contractual contingent performance metrics in accordance with ASC 805. By comparing these estimates to the agreed-upon metrics, the Company estimates the amount, if
any, anticipated to be paid to the sellers in accordance with the contractual terms. For obligations payable at a date greater than twelve months from the acquisition date, the Company applies an appropriate discount rate, which is intended to
reflect the risks of ownership and the associated risks of realizing the stream of projected cash flows, in order to present value the estimated obligations. Subsequent to the date of acquisition, the Company updates the original valuation to
reflect updated projections of future results of the acquired companies and the passage of time. Changes in the valuations of contingent consideration are reported in acquisition transaction expenses on the Consolidated Statements of Operations.
This disclosure regarding the Company’s contingent consideration obligations is included in Note 10 and further summarized in Note 11 in the 2010 Form 10-K. The Company believes this disclosure provides the reader of its financial statements
with an understanding of the nature and associated accounting treatment of its contingent consideration obligations.

 Certain of the
Company’s agreements relating to acquisitions provide for fixed amounts of deferred purchase consideration payments to be made at future dates. A liability is established at the time of the acquisition for these fixed payments. For obligations
payable at a date greater than twelve months from the acquisition date, the Company applies a discount rate to present value the obligations. The Company agrees that additional disclosure regarding the nature and accounting treatment of its deferred
purchase consideration payments would provide useful information to readers of its financial statements and has included such disclosure in Note 6 of its March 31, 2011 Form 10-Q and will continue to do so in its future filings.

Notes to the Financial Statements

Note 2. Long-Lived Assets

 -
Definite-lived Intangibles, page 88

 Comment 5: We note your disclosure that due to a change in estimate in certain
revenue-generating contracts, the Company recorded $5.9 million of additional amortization expense during 2009. Please explain to us the nature of this change in estimate and tell us why you believe it was appropriate to record this change in
estimate in 2009.

 Response: The additional amortization is related to capitalized contract acquisition rights for certain long-term
artist arrangements. Upon the execution of these contracts, due to their long-term nature and the projected timing of the net cash flows to be received, the Company applied a units-of-production method of amortization using contribution margin as
the unit of measure on which to calculate amortization during the life of the contract. However, as the Company gained experience under these contracts, the Company concluded in 2009 that, while the assets were determined to be recoverable, a
pattern of consumption of the benefits could no longer be reliably predicted for certain revenue streams due to the reliance on information from, and decisions by, third parties and therefore that a straight-line method of amortization should be
used for the portion of the assets related to that activity.

 - 5 -

 - Goodwill, page 89

 Comment 6: We note your disclosure that you are in the process of finalizing the acquisition accounting for recent acquisitions which could result in a change to the relevant purchase price
allocations including goodwill. Please tell us if you have finalized the acquisition accounting for your recent acquisitions since this disclosure and if so, please tell us the nature and amount of any significant adjustments recorded.

Response: The status of the accounting for 2010 acquisitions accounted for as business combinations is as follows:

•

 Acquisition accounting for the following 2010 acquisitions was finalized as of December 31, 2010: Ticketmaster Entertainment, Inc.; Live
Nation-Haymon Ventures, LLC; and SME Entertainment Group.

•

 In the first quarter of 2011, the Company finalized the acquisition accounting for the following 2010 acquisitions: Live SRL (Live in Italy) and Marcy
Musik Management. No significant measurement period adjustments were recorded in 2011 for these acquisitions.

•

 Acquisition accounting for the following 2010 acquisitions has not yet been finalized: Gellman Management LLC (October 2010) and Ticketnet S.A.
(November 2010). There were no measurement period adjustments recorded in the first quarter of 2011 related to Gellman. Measurement period adjustments were recorded in the first quarter of 2011 for the Ticketnet acquisition and were attributable to
a revised external valuation of intangible assets, and the related deferred tax impact, as well as cash received for a working capital adjustment. The impacts of these adjustments were: an increase in Definite-lived intangible assets–net of
$3.2 million; an increase in Cash and cash equivalents of $0.3 million; a decrease in Goodwill of $1.7 million; and a decrease in Long-term deferred income taxes of $1.8 million. The impact to Depreciation and amortization from the revision of the
intangible assets that was related to prior reported periods was an additional $0.2 million.

 -Long-Lived Asset
Disposals, page 92

 Comment 7: We note your disclosure that the sales price for the theater management agreement in September
2009 included a contingent earn-out to be paid over the next five years. Please tell us and disclose in the notes to the financial statements in future filings the terms of this contingent earn-out and how you will account for any amounts if earned.

 - 6 -

 Response: The terms of the agreement required the buyer to pay the Company the following contingent
payments:

•

 If the theater management agreement generates 2009 EBITDA in excess of a specified annual dollar threshold, prorated for the number of days occurring
from the closing date through December 31, 2009, the buyer will pay to the Company such excess up to the prorated amount, as well as 50% of any remaining portion of the excess; and

•

 If the theater management agreement generates annual EBITDA in excess of a specified dollar threshold in any calendar year from 2010 through 2014,
immediately following that calendar year, the buyer will pay to the Company such excess up to the specified dollar threshold, as well as 50% of any remaining portion of the excess.

As current authoritative accounting literature does not specifically prescribe a seller’s accounting for contingent payments to be received as part
of an asset sale, the Company’s policy is to recognize a receivable, and the related income, for any contingent payment once it has been earned and is therefore due to the Company. Based upon information received from the third-party buyer, no
payment was earned by the Company for 2009 or 2010 and no receivables have been recorded.

 The Company did disclose the existence of the
contingent