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SEC Letter

 May 17, 2012

 Mr. Larry Spirgel

 Assistant Director

Securities and Exchange Commission

 Division of
Corporation Finance

 Mail Stop 3720

100 F. Street, N.E.

 Washington, D.C. 20549-0306

 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. Spirgel:

 This letter responds to the comment letter (the “Comment Letter”) from the Staff of the Securities and Exchange Commission (the “Staff” or the “Commission”), dated
May 4, 2012, concerning the Annual Report on Form 10-K for the fiscal year ended December 31, 2011 (the “2011 Form 10-K”) of AMC Networks Inc. (“we” or the “Company”) filed on March 15, 2012.

The Company appreciates the efforts of the Staff in this review process. Enhancement of the overall disclosures in our filings is an
important objective of the Company. In connection with responding to the Staff’s comments, we acknowledge that (i) the Company is responsible for the adequacy and accuracy of the disclosures in our filings; (ii) that the Staff comments or
our changes to disclosure in response to the Staff comments do not foreclose the Commission from taking any action with respect to the 2011 Form 10-K; and (iii) the Company may not assert Staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

 For reference purposes, the comments
of the Staff’s May 4, 2012 letter have been reproduced in this letter with the text in bold and the Company’s responses are set forth directly following the reproduced comments. The section sub-header and page number in each comment
refers to the 2011 Form 10-K.

 In each of the Company’s responses below where the Company indicates it will provide
revised disclosures in the future, we have indicated the quarterly filing in which the Company will begin including such disclosures, which will be no later than the Quarterly Report on Form 10-Q (“Form 10-Q”) for the quarter ending
June 30, 2012.

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 Form 10-K for the fiscal year ended December 31, 2011

Management’s Discussion and Analysis of Financial 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 significantly in scripted
originals on AMC. In this regard, please consider discussing, in the business overview section of your MD&A, your past and future initiatives and strategies in programming. It appears that this disclosure may provide investors insight into
material opportunities, challenges and risks, such as those presented by known material trends and uncertainties, on which you are most focused for both the short and long term, as well as the actions you are taking to address these opportunities,
challenges and risks. For additional guidance, refer to Item 303 of Regulation S-K as well as Part Four of the Commission’s Interpretive Release on Management’s Discussion and Analysis of Financial Condition and Results of Operation
which is located on our website at: http://www.sec.gov/rules/interp/33-8350.htm.

 Company Response: Consistent with
the guidance in Section 501.12 of the Financial Reporting Releases, the Company has sought to avoid repetitive disclosure in the 2011 Form 10-K when discussing its past and future initiatives and strategies in programming. The Company believes
that the discussion in our fourth quarter earnings call where the Company discussed its strategy of focusing on original programming and more specifically scripted originals is consistent with the description of these initiatives and strategies
contained in Item 1. Business of the 2011 Form 10-K. The Company also describes risks associated with our original programming strategy in Item 1A. Risk Factors of the 2011 Form 10-K. The following are several excerpts from the 2011 Form
10-K where the Company believes the Staff’s comment has been addressed. With respect to programming, on pages 4 and 5 under the headings “OUR STRENGTHS” and “OUR STRATEGY,” the Company states the following:

OUR STRENGTHS

 Compelling Programming. We continually refine our mix of programming and, in addition to our popular film content, have increasingly focused on highly visible, critically-acclaimed original
programming, including the award-winning Mad Men, Breaking Bad and The Walking Dead, which in 2011 was cable television’s highest rated drama ever among adults aged 18-49 and 25-54. Other popular series include The
Killing, Hell on Wheels, Braxton Family Values, Bridezillas, Portlandia and The Increasingly Poor Decisions of Todd Margaret. Our focus on quality original programming, targeting specific audiences, has allowed
us in recent years to increase our programming networks’ ratings and their viewership within these respective targeted demographics.

 OUR STRATEGY

 Our strategy is to maintain and improve our
position as a leading programming and entertainment company by owning and operating several of the most popular and award-winning brands in cable television that create engagement with audiences globally across multiple media and distribution
platforms. The key focuses of our strategy are:

 Continued Development of High-Quality Original
Programming. We intend to continue developing strong original programming across all of our programming networks to enhance our brands, strengthen our relationships with our viewers, distributors and advertisers, and increase distribution and
audience ratings. We believe that our continued investment in original

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programming supports future growth in our two principal revenue streams — affiliation fee revenue from our distributors and advertising revenue. We also intend to continue to expand the
exploitation of our original programming across multiple media and distribution platforms.

 Increased
Control of Content. We believe that control (including long-term contract arrangements) and ownership of content is becoming increasingly important, and we intend to increase our control position over our programming content. We currently
control, own or have long-term license agreements covering significant portions of our content across our programming networks as well as in our independent film distribution business operated by IFC Films. We intend to continue to focus on
obtaining the broadest possible control rights (both as to territory and platforms) for our content.

 The Company describes the following
challenge to its original programming strategy in Item 1. Business of the 2011 Form 10-K on page 14, under the heading “COMPETITION:”

 COMPETITION

 Sources of Programming

We also compete with other programming networks to secure desired programming. Most of our original programming and all of
our acquired programming is obtained through agreements with other parties that have produced or own the rights to such programming. Competition for this programming will increase as the number of programming networks increases. Other programming
networks that are affiliated with programming sources such as movie or television studios or film libraries may have a competitive advantage over us in this area.

 The Company also describes the following risk to its original programming strategy in Item 1A. Risk Factors of the 2011 Form 10-K on page 19:

Our programming networks’ success depends upon the availability of programming that is adequate in quantity
and quality, and we may be unable to secure or maintain such programming.

 Our programming
networks’ success depends upon the availability of quality programming, particularly original programming and films, that is suitable for our target markets. While we produce some of our original programming, we obtain most of the programming
on our networks (including original programming, films and other acquired programming) through agreements with third parties that have produced or control the rights to such programming. These agreements expire at varying times and may be terminated
by the other party if we are not in compliance with their terms.

 We compete with other programming networks to
secure desired programming. Competition for programming has increased as the number of programming networks has increased. Other programming networks that are affiliated with programming sources such as movie or television studios or film libraries
may have a competitive advantage over us in this area. In addition to other cable programming networks, we also compete for programming with national broadcast television networks, local broadcast television stations, video-on-demand services and
Internet-based content delivery services, such as Netflix, iTunes and Hulu. Some of these competitors have exclusive contracts with motion picture studios or independent motion picture distributors or own film libraries.

We cannot assure you that we will ultimately be successful in negotiating renewals of our programming rights agreements or
in negotiating adequate substitute agreements in the event that these agreements expire or are terminated.

 However, in future filings,
beginning with the June 30, 2012 Form 10-Q, the Company will include the following disclosure in the Business Overview section of Management’s Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”),
highlighting some of our past and future initiatives and strategies in programming:

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 To an increasing extent, the success of our business depends on original
programming, both scripted and unscripted, across all of our networks. In recent years, we have introduced a number of scripted original series, primarily on AMC, that have been critically acclaimed, award winning and commercially successful. These
successful series have resulted in higher audience ratings for our networks. Historically, in periods when we air original programming, our ratings have increased. In 2012, AMC expects to air five scripted original series. This may result in higher
audience ratings for AMC. Among other things, higher audience ratings drive increased revenues particularly through higher advertising revenues. The timing of exhibition and distribution of original programming varies from period to period, which
results in greater variability in our revenues, earnings and cash flows from operating activities.

 Scripted
original series require us to make up-front investments, which are often significant amounts. Not all of our programming efforts are commercially successful, which could result in a write-off of program rights. If it is determined that film or other
program rights have no future programming usefulness based on actual demand or market conditions, a write-off of the unamortized cost is recorded in technical and operating expense. For example, in 2011, we recorded program rights write-offs of
$18.3 million, of which approximately $17.6 million related to one scripted original series.

 See “ —
Critical Accounting Policies and Estimates” for a discussion of the amortization and write-off of program rights.

2.
We note your disclosure on page 40 stating that “We present AOCF as a measure of our ability to service our debt and make continuing investments”. If you
use this measure as a measure of liquidity, you should reconcile this measure to cash flows from operations. Please revise or advise.

 Company Response: The Company uses adjusted operating cash flow (“AOCF”) as a measure for evaluating its operating performance on both a business segment and consolidated basis.
Accordingly, the Company presents a reconciliation of AOCF to operating income, the most directly comparable measure under generally accepted accounting principles. As discussed in the Liquidity and Capital Resources section of the MD&A, on page
57 of the 2011 Form 10-K, cash generated from operating activities is the financial metric that the Company primarily uses to measure its ability to service debt and make continuing investments. The Company does not use AOCF as a measure of
liquidity. Therefore, beginning with the March 31, 2012 Form 10-Q, the Company’s disclosure has been modified by deleting the sentence in the “Business Overview” section of the MD&A that stated, “We present AOCF as a
measure of our ability to service our debt and make continuing investments.”

 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 where you described the increases in revenue. For example on page 45 you state that advertising 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

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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 order 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
prices or to increases in the volume or to the introduction of new programming.

 Company Response: As required by
Item 303 of Regulation S-K, the Company discloses and quantifies the material items affecting its results of operations. With respect to the increase in revenues, the Company provided in the 2011 Form 10-K a discussion of the significant items,
including the dollar amounts, that impacted revenue for the reported period by reportable segment, and the Company believes that the quantified factors represent the material changes to revenue for both the National Networks and the International
and Other reportable segments. In addition, the increase in advertising revenues in 2011 as compared to 2010 was principally attributable to increased pricing, which the Company disclosed when it explained that the increase in advertising revenues
of $49.8 million was the result of higher pricing per unit sold resulting from higher ratings, consistent with the requirements of Item 303(a)(3) of Regulation S-K. With respect to affiliation fee and other revenue, in future filings the
Company will provide additional disclosure regarding whether the increase is primarily price or volume driven, consistent with language in the Company’s Form 10-Q for the period ended March 31, 2012 which states, “…increase in
affiliation fee revenues of $11,366, primarily attributable to an increase in rates, including the impact of lower amortization of deferred carriage fees…” In addition, in future filings, beginning with the June 30, 2012 Form 10-Q,
the Company will provide a comparative table for each reportable segment presenting separately revenues from advertising and from affiliation fee and other revenues. Please see the Company’s response to Comment 8 below for a sample of such
tabular disclosure.

 In the paragraph immediately following the Company’s disclosure of the material changes in revenues affecting the
periods included in the 2011 Form 10-K, and in an effort to provide additional insight to investors into some of the variables that generally cause revenues to change from period to period, the Company made the statement “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.” This statement is a general
explanation of variables affecting revenue and was intended to supplement the discussion and quantification of the specific material changes affecting the revenue for the particular period. To clarify this point,