SecProbe.io

August 21, 2018
Sean Sullivan
Executive Vice President and Chief Financial Officer
AMC Networks Inc.
11 Penn Plaza
New York, NY 10001
Re:AMC Networks Inc.
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed March 1, 2018
Form 10-Q for the Quarterly Period Ended June 30, 2018
Filed August 2, 2018
File No. 001-35106
Dear Mr. Sullivan:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-Q for the Quarterly Period Ended June 30, 2018
Content licensing revenue, page 7
1.Please provide us your analysis regarding identifying performance obligations in your
content licensing arrangements.  Tell us if these arrangements contain content libraries
and, if so, how you have considered whether existing content and new content represent
separate performance obligations.  In addition, please clarify how you have considered
judgments in determining both amounts allocated to and the timing of satisfaction of the
related performance obligations.  Refer to ASC 606-10-50-12 and ASC 606-10-50-17.

 FirstName LastNameSean Sullivan
 Comapany NameAMC Networks Inc.
 August 21, 2018 Page 2
 FirstName LastName
Sean Sullivan
AMC Networks Inc.
August 21, 2018
Page 2
Subscription fee revenue, page 7
2.Please help us better understand the nature of services transferred to your customers
within your affiliation agreements.  Tell us if you have combined any services for the
purposes of determining your performance obligations.  Specifically address whether
these arrangements contain a video-on-demand library.  Please also describe the
judgement used in determining both the timing of satisfaction and amounts allocated to
each performance obligation.  Refer to 606-10-50-12 and 606-10-50-17.
3.Please tell us your basis for recognizing revenue related to your fixed fee affiliation
agreements based on the invoiced amount or on a straight-line basis.  In this regard, tell us
if you believe these arrangements contain a functional license of intellectual property.
Note 2. Revenue Recognition
Advertising, page 8
4.We note certain advertising contracts have guarantees of audience member views.  We
also note your disclosure at the bottom of page 8 that a portion of the related revenue is
deferred if the guaranteed ratings are not met.  Please clarify if these guarantees are
treated as variable consideration in determining your transaction price.  Refer to ASC 606-
10-32-5 and 606-10-50-20.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or Carlos
Pacho, Senior Assistant Chief Accountant at 202-551-3835 with any questions.
Sincerely,
Division of Corporation Finance
Office of Telecommunications