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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 10, 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 8, 2020

File No. 005-19132

File No. 001-06961

Dear Mr. Shainess:

We refer
to your letter, dated April 8, 2020, with comments to (i) Amendment No. 3 to Schedule 13D filed on April 1, 2020 by Standard General
L.P. (“Standard General”) and Mr. Kim, (ii) Amendment No. 4 to Schedule 13D filed on April 3, 2020 by Standard General
and Mr. Kim, and (iii) the definitive additional materials on Schedule 14A filed on April 7, 2020 by Standard General and the other
participants named therein with respect to TEGNA Inc. (“TEGNA”). Please see below our responses to your comments.

Amendments No. 3 and 4 to
Schedule 13D

 1. We note that you conducted sales of five million shares of TEGNA
stock in March following the March 20 record date for TEGNA’s annual meeting. Given that these sales took place after the
record date, please advise us as to whether you have retained the right to vote these shares at the annual meeting, and if so,
why your soliciting materials and Schedule 13D amendments filed April 1 and April 3, 2020 do not reflect the beneficial ownership
of these shares.

As disclosed in a Schedule 13D
amendment filed on March 18, 2020, on March 16, 2020, Standard General executed the settlement of swaps with respect to 2,015,362
shares of common stock previously entered into with unaffiliated third-party financial institutions, with those swaps physically
settling for 2,015,362 shares of common stock on March 18, 2020. The Schedule 13D amendment clearly states that as of that date
the reporting persons beneficially owned 21,124,315 physical shares.

As disclosed in its Schedule
13D amendment filed April 1, 2020, of the 21,124,315 shares of common stock previously reported as being beneficially owned by
the reporting persons, in a series of transactions during March 25, 2020 through March 31, 2020, the reporting persons sold an
aggregate of 5,000,000 shares of common stock and entered into swaps with respect to an aggregate of 5,000,000 shares of common
stock with unaffiliated third-party financial institutions. Since the record date for TEGNA’s 2020 annual meeting was March
20, 2020, the change in the form of ownership of those shares after the record date had no effect on the voting rights of the reporting
persons.

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Fried, Frank, Harris, Shriver
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Fried, Frank, Harris, Shriver & Jacobson LLP

    April 10, 2020

    Page 2

We respectfully note that we
do not believe any affirmative disclosure was required under the 13D rules that the reporting persons retained the right to vote
shares sold after the record date, as that is the effect under state law of being the owner as of the record date. A different
result would obtain only if the reporting persons had entered into a voting agreement empowering a third party to direct the vote
of those shares. Had the reporting persons entered into any such agreement, they would, of course, have disclosed that agreement.
However, there is no such agreement.

To the extent there was any ambiguity
as to this matter (and we believe there was none), in its Regulation 14A filing on April 9, 2020, Standard General affirmed that
it has the right to vote the shares held by the reporting persons as of the record date.

As disclosed in its Schedule
13D amendment filed April 3, 2020, on April 2, 2020, the reporting persons purchased 4,591,164 shares of common stock, and reported
shared voting and dispositive power over 25,715,479 shares of common stock.

The Staff’s comment appears
to suggest that the reporting persons should disclose voting power over an additional 5,000,000 shares. We respectfully
disagree with the Staff’s suggestion. At March 20, 2020, the reporting persons had shared voting and dispositive power over
21,124,315 shares of common stock. The execution of swaps and purchases of shares after the record date did not affect the fact
that, as of the March 20 record date, the reporting persons had voting and dispositive power over 21,124,315 shares. As is reflected
in the 13D amendment filed April 3, the reporting persons currently hold voting and dispositive power over 25,715,479 shares of
common stock, inclusive of 5,000,000 shares underlying swaps. Although there is no voting agreement with respect to the 5,000,000
swap shares, the reporting persons report shared voting power over those shares because they have the right to settle the swaps
for physical shares.

As to any hypothetical record
date other than March 20, 2020, the reporting persons’ actual voting power would depend upon the form and amount of the reporting
persons’ beneficial ownership as of that record date. Assuming, for illustrative purposes, that the reporting persons were
to continue to hold the number of shares currently reported and to physically settle all swaps currently held by them prior to
that record date, the number of shares over which they would have voting power would correspond to the 25,715,479 shares currently
reported.

 2. Please amend your Schedule 13D to disclose the information required
by Item 6, including a description of the swap arrangements, the identity of the counterparties, and any associated voting arrangements
with those counterparties. Additionally, file as an exhibit the arrangements relating to the transfer or voting of the subject
shares as required by Item 7.

Fried, Frank, Harris, Shriver & Jacobson LLP

    April 10, 2020

    Page 3

The reporting persons will file
an amendment to the Schedule 13D to expand their disclosure with respect to the swaps to identify the number of shares, notional
amount, interest rate and counterparty to these swaps, and will confirm that there is no voting agreement with respect to the shares
underlying the swaps. We note that this is more detail than is customarily provided by 13D filers with respect to standard form
derivatives transactions.

As we have discussed with you,
other than customary trade confirmations, which are subject to standard ISDA terms and which do not confer any right to vote or
direct the vote of the underlying shares, there are no agreements relating to the transfer or voting of the subject shares. We
note that prominent activists such as Carl Icahn and Elliott Associates do not file trade confirmations as Item 7 exhibits, and
believe that the approach taken by Standard General complies with applicable law.

Definitive Additional Materials on Schedule
14A filed April 7, 2020

 3. We note the disclosure of your “ownership interest of nearly
12% of the Company’s outstanding shares.” In future filings, where you discuss your ownership of TEGNA shares, please
also disclose the form of such share ownership, both in terms of your economic and voting interests, in order to provide proper
context.

We note the Staff’s
comment and will, accordingly, make this disclosure in our future filings.

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.