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November 12, 2024
VIA EDGAR TRANSMISSION
Securities and Exchange Commission
Division of Corporation Finance
100 F Street NE
Washington, D.C. 20549-3561
Attention: Valeria Franks
Suying Li
Re: AMC Entertainment Holdings, Inc.
Form 10-K for Year Ended December 31, 2023
Item 2.02 Form 8-K filed August 2, 2024
Response dated October 9, 2024
(File No. 001-33892)
To the addressees set forth above:
AMC Entertainment Holdings, Inc. (the “Company, “we, “us,” and “our”) respectfully submits this
response to the comments set forth in the comment letter of the staff of the Division of Corporation Finance (the
“Staff”) of the Securities and Exchange Commission dated October 31, 2024. For your convenience, we have
repeated your comments below in bold and italics before each of our responses.
Item 2.02 Form 8-K filed August 2, 2024
Exhibit 99.1
Reconciliation of Contribution Margin Per Patron
1. We read your response to prior comment 2. Please respond to address the following:
 Please disclose in greater detail the reasons why you believe the presentation of contribution
margin and contribution margin per patron provides useful information to investors and additional
purposes for which management uses these non-GAAP measures. Refer to Items 10(e)(1)(i)(C) and
(D) of Regulation S-K.
The Company acknowledges the Staff’s comment and advises the Staff that it believes that non-GAAP
contribution margin and contribution margin per patron are useful and very important performance measures for
our investors, as these measures provide investors with a view of how much profit is generated by our movie-goer
patrons before the inclusion of fixed costs.
The revenues generated by our theatres are essentially variable and depend in large part on attendance
levels by our customers at our theatres. At the same time, a significant portion of our operating costs and expenses
are fixed, including, for example, payroll and theatre rent. Contribution margin is a key performance measure
used to measure the impact on our profitability of differing attendance levels, after deducting the direct variable
costs associated with those attendance levels, but before recognizing the impact of fixed operating costs and

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expenses that do not vary directly with attendance. Contribution margin per patron is the total contribution dollars
divided by number of customers served. Thus, contribution margin per patron provides a measure of the
incremental profitability generated by a patron, by providing the incremental dollars earned or (lost) per customer
gained or (lost).
These metrics are key performance measures that we use internally, as they allow us to measure the
incremental impact on profitability of changes in our attendance levels. For the same reason, we believe these
measures are valuable metrics for investors, particularly given the varying levels of attendance in our industry.
These measures allow us and our investors to evaluate the impact on profitability of important business decisions
we make, such as product pricing and food and beverage offerings and initiatives. Thus, we believe that
presenting these performance measures provides greater transparency to our investors on how we operate our
business and how our business is performing including how efficiently the Company is managing its variable
costs relative to its revenue.
We believe this transparency is particularly important to our investors, given the recent challenges
experienced by our industry, which has had a significant impact on attendance levels. Our attendance levels have
varied significantly since the COVID-19 shutdowns in 2020 and subsequent movie industry labor stoppages and
are expected to continue to vary as the extended industry recovery proceeds. Current attendance levels are
approximately 25% below pre-COVID-19 levels. Providing investors with the contribution margin metric
increases the utility of the aggregate financial information available as it allows investors to understand and model
the variable impact of past, present, and projected future attendance levels.
Contribution margin supplements our other non-GAAP profitability measure, Adjusted EBITDA, which
does include all rent and operating costs, by providing our investors with additional information to evaluate
changes in GAAP profit measures as attendance varies, and we believe that quantifying the financial impact of
attendance level changes with the contribution per patron metric will continue to be important to our investors. As
evidence of the usefulness of these measures, we note that it is our experience that multiple equity research
analysts utilize contribution margin in their coverage of our industry and business.
In that regard, we also note that our measure of contribution margin is similar to how certain retailers may
measure GAAP gross profit. Contribution margin, like GAAP gross profit, represents the dollar contribution from
transactions with customers excluding fixed operating costs and expenses that are not impacted by changing
attendance levels.
Similar to GAAP gross profit used by certain others, contribution margin is equal to GAAP revenue less
GAAP costs directly associated with revenue. Film exhibition costs that we pay film studios and food and
beverage costs are our direct variable expenses associated with our revenues. So, for the same reasons that certain
others might report GAAP gross profit, we believe it is useful to provide our measure of contribution margin.
In light of the Staff’s comments, we will add the following additional disclosure to future filings:
We present “contribution margin” and “contribution margin per patron” as supplemental measures of our
performance. We define “contribution margin” as Revenue less both Film Exhibition Costs and Food and
Beverage Costs. These costs are directly variable with attendance. Contribution margin per patron is the total
contribution margin divided by number of customers served. The “contribution margin per patron” thus represents
the incremental dollars earned or (lost) per customer gained or (lost). We believe contribution margin and
contribution margin per patron are key performance measures that provide investors with supplemental
information regarding (i) the impact to our profitability of differing attendance levels, after deducting the direct
variable costs associated with those attendance levels, but before recognizing the impact of fixed operating costs
and expenses that do not vary directly with attendance and (ii) our ability to cover fixed costs that do not vary
directly with attendance. We believe this is particularly important information given the significant variability in
attendance levels in our business and our industry.

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“Contribution margin” has important limitations as an analytical tool and should be evaluated only in
conjunction with our results as reported under US GAAP and other performance measures such as Adjusted
EBITDA. Our definition of “contribution margin” as set forth in the reconciliation above, is the equivalent of
GAAP gross profit after adding back Operating expense, excluding depreciation and amortization expense; Rent,
and Depreciation and amortization expense, which in each case are otherwise included in cost of revenue. As a
result, while “contribution margin” is designed to focus on the impact of directly variable costs, it excludes
normal, recurring, operating expenses that do not vary directly with attendance but which nevertheless directly
impact our profitability.
 Please tell us in greater detail with quantification the types of operating expenses that are included
in the "operating expense, excluding depreciation and amortization expense, cost of revenues" line
item.
Expenses included in “operating expenses, excluding depreciation, amortization expense, cost of
revenues” are as follows:
Nine Months Ended Twelve Months Ended
September 30, December 31,
(In millions) 2024 % of Total 2023 % of Total
Operating expense, excluding depreciation
and amortization expense, cost of revenues:
Payroll $ 545.7 44.1% $ 731.8 43.3%
Utilities 119.4 9.6% 171.1 10.1%
Repairs and maintenance 110.5 8.9% 142.3 8.4%
Property tax 90.0 7.3% 119.8 7.1%
Equipment expense 53.3 4.3% 64.8 3.8%
Theatre operating expense 319.0 25.8% 461.7 27.3%
Operating expense, excluding depreciation
and amortization expense, cost of revenues $ 1,237.9 100.0% $ 1,691.5 100.0%
 Please tell us why you believe "rent, cost of revenues" and "operating expense, excluding
depreciation and amortization expense, cost of revenues" do not represent normal, recurring, cash
operating expenses necessary to operate your business and your consideration of Question 100.01
of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations in determining
the appropriateness of these adjustments.
We exclude “operating expenses, depreciation and amortization expense, cost of revenues” from our
contribution margin calculation because a significant portion of these costs are fixed and do not vary with
attendance.
Similarly, we exclude rent expense from our calculation of contribution margin because rent is a fixed
cost that does not vary with attendance.
The Company considers that both “rent” and “operating expense, excluding depreciation and
amortization expense” to be normal recurring, cash operating expenses necessary to operate our business. These
expenses are included in our GAAP Net Income and non-GAAP Adjusted EBITDA. However, the Company
maintains that the measure of contribution margin is not intended to be a measure of total profitability but as
described above, the very aim of the measure is to aid us and investors in measuring the incremental impact on
profitability of varying attendance levels, before the impact of fixed costs, including fixed cash costs that are
normal and recurring. Therefore, these expenses are excluded from contribution margin because they are expenses
that do not vary directly with attendance. Including these costs would be contrary to the aim of these measures

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and defeat their usefulness to us and to investors to provide additional information about our operating
performance.
Additionally, the Company has reviewed the requirements of Rule 100(b) of Regulation G and the
guidance in the Compliance and Disclosure Interpretations, including Question 100.01, and based upon such
review, does not believe that the adjustments for rent and other operating expenses violate Rule 100(b) of
Regulation G as the Company does not believe the exclusion of these expenses could cause the measure of
contribution margin to be misleading to an investor. We do not believe our current presentation of contribution
margin would mislead an investor given its context as an additional measure of profitability that supplements our
existing presentation of Adjusted EBITDA, which does include these normal, recurring, cash operating expenses.
We also believe our disclosures (including our enhanced disclosures described above), together with the more
prominent GAAP information we provide, our supplementary non-GAAP measures, and the full GAAP
reconciliations presented, provide investors with the information and ability to make their own judgments
regarding the usefulness of the information and preclude the disclosures from being misleading. To the contrary,
we believe the presentation of contribution margin increases the decision-usefulness of the aggregate information
provided to our investors as it identifies costs by nature – fixed vs. variable – in order for an investor to better
evaluate profitability of our business over time and at different attendance levels. Further, the amounts used to
arrive at these non-GAAP measures all appear on the face of the Company’s consolidated statement of operations
or in the notes to the financial statements and do not otherwise eliminate or accelerate any amounts in
contravention of GAAP.
The Company further respectfully advises the Staff that its treatment of rent and other operating expenses
in its presentation of contribution margin is reflective of how management views and operates the Company’s
business. The Company’s management focuses on how fixed expenses and revenue vary from period to period,
and the relationship between its fixed expenses and revenue, and contribution margin and contribution margin per
patron provide a comparable metric that facilitates management’s ability to identify operational trends, make
decisions regarding future spending, resource allocation, and other operational decisions. The Company has
presented these metrics to provide investors with the same degree of visibility into the profitability of the business
as management.
In summary, the Company respectfully advises the Staff that it believes the adjustments for rent and
operating expense, excluding depreciation, is in compliance with non-GAAP rules and we will provide additional
clarification in future filings to ensure it aligns with the guidance in Question 100.01 of the Non-GAAP Financial
Measures Compliance and Disclosure Interpretations. We believe this measure is important to investors in the
same way it is important to us. Finally, as noted above, this measure is also extensively used by equity research
analysts who cover our industry to better understand our operating economics, and we have provided some
examples of the analyst reports in our response, as supplemental information for the Staff.
***
We further acknowledge that we are responsible for the adequacy and accuracy of the disclosures in
our filings, not notwithstanding any review, comments, action or absence of action by the Staff.
Should any questions arise in connection with the filing or this response letter, please contact the undersigned at
(913) 213-2191.
Sincerely yours,
/s/ Chris A. Cox
Chris A. Cox
Senior Vice President and Chief Accounting Officer

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Attachments
Wold, E., May 9, 2024, Upside 1Q24 Results—Remain Positive on Opportunity for Box Office Share Gains
and Reduced Debt Overhang to Boost the Valuation
Wold, E., July 7, 2024, Exhibition Industry 2Q24 Previews—Don't Let the Box Office Make You “Furiosa;”
Goss, James, C., Sholl, P. W., November 9, 2023, Q3/23 Initial: Record Performance Supported by PLF Base
Goss, James, C., Sholl, P. W., November 16, 2023, Operating Results Rebounding Nicely, but Financial
Challenges Remain

 AMC Entertainment Holdings, Inc. (AMC – $3.19*)
Consumer: Media & Entertainment
Neutral; $8.00 PT; $943.0M Market Cap
Raise Estimates
Thursday, May 9, 2024
Upside 1Q24 Results—Remain Positive on Opportunity for Box Office Share Gains
and Reduced Debt Overhang to Boost the Valuation; Maintain Neutral, $8 PT
Eric Wold, CFA
415-229-4836
ewold@brileyfin.com
STOCK DATA
Market Cap (mil) $943.0
52-Week Range $2.38–$54.97
3-Month ADTV 16,785,626
Shares Outstanding (mil) 295.6
Float (%) 99.7
Short Interest 50,685,424
Beta 1.20
Enterprise Val. (mil) $4,914.9
Fiscal Year-End December
FINANCIAL DATA
Revenue
(mil) Calendar 2023A 2024E 2025E
1Q $954.4 $951.4A $1,023.3
Prior 1Q - $878.0 $1,034.3
2Q $1,347.9 $1,188.6 $1,416.1
Prior 2Q - $1,182.6 $1,398.4
3Q $1,405.9 $1,134.4 $1,284.0
Prior 3Q - $1,126.8 $1,266.3
4Q $1,104.4 $1,244.0 $1,427.6
Prior 4Q - $1,235.4 $1,407.0
FY $4,812.6 $4,518.4 $5,151.0
Prior FY - $4,422.8 $5,106.0
Adj.
EBITDA Calendar 2023A 2024E 2025E
1Q $7.1 $(31.6)A $(10.4)
Prior 1Q - $(38.1) $18.8
2Q $182.5 $116.9 $218.1
Prior 2Q - $121.2 $209.8
3Q $193.7 $50.6 $98.9
Prior 3Q - $48.7 $84.0
4Q $42.5 $182.8 $261.4
Prior 4Q - $177.5 $241.3
FY $425.8 $318.6 $567.9
Prior FY - $309.3 $553.9
EV/Adj. EBITDA 11.5x 15.4x 8.7x
BALANCE SHEET DATA
1Q24
Cash & Equivalents $624.2
Total Debt $4,543.0
Shareholders' Equity $(2,031.0)
millions unless otherwise specified.
Summary and Recommendation
On Wednesday, 5/8 AMC, AMC Entertainment Holdings, Inc. (AMC—Neutral, $8 PT) reported
1Q24 results that exceeded expectations from continued box office market share gains and
theater-