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    Fried,
                                         Frank, Harris, Shriver & Jacobson LLP

        One New York Plaza

        New York, New York 10004

        Tel:	+1.212.859.8000

        Fax:	+1.212.859.4000

        www.friedfrank.com

    April 9, 2020

Via E-mail

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 Attention: Joshua Shainess, Esq.

Special
Counsel

Office of Mergers and Acquisitions

 Re: TEGNA Inc.

Response
to SEC Letter, dated April 6, 2020

File
No. 001-06961

Dear Mr. Shainess,

We refer
to your letter, dated April 6, 2020, with comments to the definitive additional materials on Schedule 14A filed on March 31, 2020
by Standard General L.P. (“Standard General”) and the other participants named therein with respect to TEGNA Inc. (“TEGNA”).
Please see below our responses to your comments.

 1. Each statement or assertion of opinion or belief
must be clearly characterized as such, and a reasonable factual basis must exist for each such opinion or belief. Support for
opinions or beliefs should be self-evident, disclosed in the proxy statement or provided to the staff on a supplemental basis.
Please provide support for the following statements:

 · “The Company
lags the operating margins and retransmission rates of its leading pure-play peers. TEGNA’s lack of operating prowess is
evident from the current performance of stations acquired by TEGNA from Belo during Mr. Lougee’s watch. In the years following
the acquisition, 9 of the top 11 stations acquired lost market share and are now ranked lower in their respective markets.”

As support for the first sentence
relating to operating margins and retransmission rates, please refer to slides 20 to 22, 24 and 34 of the Investor Presentation
filed by Standard General and the other participants named herein as definitive additional materials on Schedule 14A on April 7,
2020 (the “Investor Presentation”). Support for the next two statements relating to the performance of stations
acquired from Belo under Mr. Lougee’s watch is set forth on slide 25 of the Investor Presentation.

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 • London • Frankfurt

Fried, Frank, Harris, Shriver
 & Jacobson LLP is a Delaware Limited Liability Partnership

Fried,
Frank, Harris, Shriver & Jacobson LLP

    April 9, 2020

    Page 2

 · “TEGNA paid excessive prices for the stations
it acquired and did not create duopolies, which is the source of efficiencies and synergies that management originally touted
as a rationale for industry consolidation. Share repurchases would have been much more accretive.”

As support for these statements,
please refer to the portion of the Investor Presentation titled “Value Destructive Acquisitions and Poor Capital Allocation”
(slides 29 through 45).

 · “This annual meeting is a referendum on the
current Board’s stewardship.”

Standard General’s solicitation
materials detail, among other things, TEGNA’s record of underperformance, strategic missteps, poor governance, squandering
of opportunities to maximize shareholder value and value destruction. While Standard General believes that any proxy fight focused
on replacing members of the board of directors of a company in the context of underperformance inherently represents a referendum
on the stewardship of the incumbent directors, Standard General believes that is especially true in this instance.

Please contact Warren
de Wied at (212) 859-8296 or Phil Richter at (212) 859-8763 if you have any questions regarding this letter.

    Very truly yours,

Warren
de Wied

 CC: Gail Steiner

Partner,
General Counsel and Chief Compliance Officer

Standard
General L.P.