SecProbe.io

May 4, 2012
 Via e-mail:

Mr. Sean Sullivan Chief Financial Officer AMC Networks, Inc. 11 Penn Plaza New York, New York 10001
Re: AMC Networks, Inc.
Form 10-K for the fiscal year ended December 31, 2011 Filed March 15, 2012
  File No. 1-35106

Dear Mr. Sullivan:

 We have limited our review to only your fina ncial statements and related disclosures and
do not intend to expand our review to other porti ons of your documents.  Please comply with the
following comments in future filings.  Confirm in  writing that you will do so  and provide us with
your proposed disclosure.
  Please provide us with your proposed disclosures. In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.               Form 10-K for the fiscal year ended December 31, 2011

 Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

 Business Overview, page 38

 1. We note the discussion in your fourth quarter earnings call where you mention your strategy
of focusing in original programming, most signi ficantly in scripted originals on AMC.  In
this regard, please consider discussing, in the business overview s ection of your MD&A,
your past and future initiatives and strategies in  programming. It appears that this disclosure
may provide investors insight into material oppo rtunities, challenges and risks, such as those
presented by known material trends and uncer tainties, on which you are most focused for
both the short and long term, as well as th e actions you are taking to address these

Mr. Sullivan AMC Networks, Inc. May 4, 2012 Page 2

 opportunities, challenges and risks.  For addition al guidance, refer to Item 303 of Regulation
S-K as well as Part Four of  the Commission’s Interpreti ve Release on Management’s
Discussion and Analysis of Fina ncial Condition and Results of Operation which is located on
our website at: http://www.sec.gov/ru les/interp/33-8350.htm

2. We note your disclosure on page 40 stating th at “We present AOCF as a measure of our
ability to service our debt and make continui ng investments”.  If you use this measure as a
measure of liquidity, you should reconcile this measure to cas h flows from operations. Please
revise or advise.
 Consolidated Results of Operations, page 43

 Year Ended December 31, 2011 Compared to Year Ended December 31, 2010

 Revenues, net, page 45

 3. We note your disclosure on page 45 and 46 wher e you described the increases in revenue.
For example on page 45 you state that advertis ing revenues increased “primarily at AMC
resulting from higher ratings and higher pricing per unit sold.”  You also state that “changes
in revenue discussed above are primarily derived from changes in contractual affiliation rates
charged for our services, changes in the number of subscribers and changes in the prices and
level of advertising on our networks.”  In orde r to provide investors with insight into your
results of operations, please quantify each variable attributable to the increase in revenues.  In
addition, in accordance with Item 303(a)(3) of Regulation S-K, quantify the growth
attributable to increases in pr ices or to increases in the vol ume or to the introduction of new
programming.
 Technical and operating expense (excludi ng depreciation and amortization), page 47

 4. We refer to the significant increase in amortizat ion of program rights fo r the last two fiscal
years ended December 31, 2011 and 2010.  We al so note the discussion in your fourth
quarter earnings call where you state that you r strategy over the past several years has
focused on original programming and that you ha ve seen a ramp up in your investment in
programming.   In this regar d, please discuss if you expect to continue increasing program
rights expenditures, and whether the related increase in amorti zation of program rights is a
trend that you expect to con tinue in future periods.
 Liquidity and Capital Resources, page 57

 5. We note your disclosure on page 58 where you stat e, “Our principal uses of cash include our
debt service, the acquisition and developmen t of program rights and the net funding and
investment requirements of our de veloping services.”  In this regard, please provide a more
detailed analysis of uses of cash as it re lates to investments in  programming and other
developing services.  We noted a more detaile d discussion in your four th quarter earnings

Mr. Sullivan AMC Networks, Inc. May 4, 2012 Page 3

 call where you mention the timing and funding fo r production of new shows and the effect on
working capital as a resu lt of these investments.  Also, di scuss and analyze known trends and
uncertainties as it relates to fu ture programming expenditures.
 Critical Accounting Policies and Estimates, page 65

 Program Rights, page 67

6. For program rights, please consider modifying your critical accounting po licies and estimates
by addressing the role your policy has in unde rstanding the company’s re sults of operations.
For example, you should include disclosure sim ilar to what you discussed in your fourth
quarter earnings call, regarding why you had program write-downs and how you determined
the program write-downs. You should also disc uss any specific change s in amortization for
program rights (i.e. increase in amortizati on due to increase in revenue from market
acceptance of a particular program).  Please expand and or modify your disclosure by
analyzing to the extent possible factors such as:
 How the company arrived at the estimate;
 How accurate the estimate/assumption has been in the past;
 Whether the estimate/assumption has changed or is reasonably likely to change in
the future; and
 Evaluate the sensitivity to change of th e critical accounting policy and estimate.

Consolidated Financial Statements
 Consolidated Statement of Cash Flows, page F-5

7. It is unclear to us whether you have included all the cash receipts from the credit facility in
the cash flows from financing activities. Fo r example on page F-21 you state that you
received $1,130,000,000 and $595,000,000 (total $1,725,000,000)  from the credit facility.
However, only $1,442,364,000 is shown in the cash flow statement and nothing is shown in
Note 4 as non-cash activity. Please revise or advise.
 Notes to the Consolidated Fi nancial Statements, page F-6

 Note 13 – Segment Information, page F-31

8. It appears that in accord ance with ASC 280-10-50-40, you should disclose separately
revenues from affiliation fees and from the sale of advertising.  Please revise or advise.

9. We note that AMC, WE tv, IFC, Sundance Ch annel, and AMC Networks Broadcasting &
Technology are your reporting units.  In this re gard, tell us whether each of your reporting
units is an operating segment under ASC 280. If this is the case, please provide us with a
detailed analysis showing how the aggregati on criteria under ASC 280- 10-50-11 were met.
If you determined that your reporting units  are not operating segments under ASC 280,

Mr. Sullivan AMC Networks, Inc. May 4, 2012 Page 4

 please tell us what type  of financial information, if any, is provided to your CODM for each
of your reporting units.
Note 12.  Income Taxes, page F-28

 10. We note your disclosure on page F-14, wher e you state, “The Company provides deferred
taxes for the outside basis difference for its inve stment in partnerships.”  We also note that
you have a deferred tax liability of $107,546,000 for investments in partnerships.  In this
regard, please tell us about your investment in partnerships and how you determined the
differed tax liability.
Note 16. Equity and Long-Term Incentive Plans, page F-36

11. Please disclose your total stock-based compensati on cost related to nonve sted awards not yet
recognized as of December 31, 2011, and the we ighted-average period over which it is
expected to be recognized.   Refer to ASC 718-10-50-2(i).

Please file all correspondence over EDGAR.  We urge all persons who are responsible
for the accuracy and adequacy of the disclosure in  the filing to be certain  that the filing includes
the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules
require.  Since the company and its management  are in possession of a ll facts relating to a
company’s disclosure, they are responsible for th e accuracy and adequacy of  the disclosures they
have made.                In responding to our comments, please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure 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

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

Mr. Sullivan AMC Networks, Inc. May 4, 2012 Page 5

 You may contact Inessa Kessma n, Senior Staff Accountant, at (202) 551-3371 or Ivette
Leon, Assistant Chief Accountant, at (202) 551- 3351 if you have questions regarding comments
on the financial statements and related matters.  Please contact me at (202) 551-3810 with any
other questions.
Sincerely,  /s/ Carlos Pacho for  Larry Spirgel Assistant Director