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CORRESP
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 filename1.htm

 CORRESP

 May 1, 2025 Division
of Corporation Finance Office of Technology Securities and
Exchange Commission 100 F Street, N.E. Washington, D.C.
20549

 Attention:

 Melissa Walsh Stephen Krikorian

 Re:

 AMC Networks Inc. Form 10-K for the Fiscal Year Ended December 31, 2024 File
 No. 001-35106

 Ladies and Gentlemen: Following
our telephone conversation with Melissa Walsh on April 28, 2025, this letter is provided to supplement our response letter dated April 16, 2025.
 For reference purposes, we have set forth each comment from your initial letter dated April 7, 2025 in bold, immediately followed by the Company’s
supplemental response. Form 10-K for the Fiscal Year Ended December 31, 2024
 Notes to Consolidated Financial Statements Note 12.
Leases, page F-33

 1.
 We note your disclosure that most of your leases do not provide an implicit rate, so you use your
incremental borrowing rate. Tell us how your determination of the discount rate for your leases complies with the guidance in ASC
 842-20-30-3. That is, even though your operating leases do not provide an implicit rate, explain whether the rates implicit in
any of your leases are readily determinable from information provided in the lease. Company Response :
 In future filings, the Company will state that the rate implicit in our leases is not readily determinable and revise our disclosure to add the
following language: “Since the rate implicit in our leases is not readily determinable, the Company uses its incremental borrowing
rate based on the information available at the lease commencement date to determine the present value of the lease payments.”

 Note 20. Segment Information, page F-44

 2.
 You indicate that the chief operating decision maker (“CODM”) uses segment adjusted operating
income (“AOI”) as the measure of profit or loss for your operating segments. We note you also present operating income for each reportable segment. Tell us whether the CODM receives operating income for each reportable segment and how it
is used. If the CODM uses more than one measure of segment profit or loss, such as operating income and AOI, explain what consideration you gave to the guidance in ASC 280-10-50-28A, which indicates that at least one of the reported segment profit or loss measures shall be that which management believes is determined in accordance with the measurement principles most
consistent with those used in measuring the corresponding amounts in the consolidated financial statements. In this regard, certain disclosures are required for each reported measure of a segment’s profit or loss. See ASC 280-10-50-28C.
 Company Response : In future filings, the Company will amend its presentation in the segment footnote to include only operating income on
a consolidated basis as part of a reconciliation of segment adjusted operating income to consolidated income before income taxes, as proposed below.

 Year Ended December 31, 2024

 (In thousands)

 Domestic Operations

 International

 Total

 Revenues, net from external customers

 Subscription

 $
 1,275,127

 $
 196,924

 $
 1,472,051

 Advertising

 561,301

 115,333

 676,634

 Content licensing and other

 264,772

 7,857

 272,629

 2,101,200

 320,114

 2,421,314

 Inter-segment revenues (Content licensing and other)
 (a)

 11,789

 4,914

 16,703

 $
 2,112,989

 $
 325,028

 2,438,017

 Reconciliation of revenue

 Elimination of inter-segment revenues
 (a)

 (16,703
 )

 Total consolidated revenues, net

 $
 2,421,314

 Less: (b)

 Content expenses

 851,702

 79,989

 Marketing, research, and advertising sales expenses

 298,267

 23,842

 Other (c)

 343,441

 156,292

 Segment adjusted operating income

 $
 619,579

 $
 64,905

 $
 684,484

 Reconciliation of total segment adjusted operating income

 Elimination of inter-segment profits

 (2,228
 )

 Unallocated corporate overhead costs
 (d)

 (119,683
 )

 Share-based compensation expenses

 (26,051
 )

 Depreciation and amortization

 (98,015
 )

 Impairment and other charges

 (399,513
 )

 Restructuring and other related charges

 (49,464
 )

 Cloud computing amortization

 (13,452
 )

 Majority-owned equity investees AOI

 (15,678
 )

 Operating income (loss)

 (39,600
 )

 Other income (expense):

 Interest expense

 (166,186
 )

 Interest income

 36,803

 Loss on extinguishment of debt, net

 (105
 )

 Miscellaneous, net

 (5,409
 )

 Income (loss) from operations before income taxes

 $
 (174,497
 )

 (a)
 Inter-segment revenues primarily relate to Domestic Operations content licensing sales to International, as
well as services performed by AMCNI on behalf of businesses within the Domestic Operations segment.

 (b)
 The significant expense categories and amounts align with the segment-level information that is regularly
provided to the CODM.

 (c)
 Other for each reportable segment primarily includes employee-related costs, information technology costs,
professional services expenses, occupancy expenses, certain overhead expenses and the Company’s proportionate share of adjusted operating income (loss) from majority-owned equity method investees.

 (d)
 Unallocated corporate overhead costs include costs such as executive salaries and benefits and costs of
maintaining corporate headquarters, facilities and common support functions.

 In future filings, the Company will also amend its presentation of the below tables in Management’s
Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”) to conform to the updates in the segment footnote. The
 ‘Financial Highlights’ table previously presented revenues, operating income, and adjusted operating income on a segment basis. The Company will amend its presentation to present these amounts on a consolidated basis, as proposed
below. Financial Highlights
 The tables presented below set forth our consolidated revenues, net, operating income (loss) and adjusted operating income (loss)
(“AOI”) 1 , for the periods indicated.

 (In thousands)

 Year Ended December 31,

 2024

 2023

 Revenues, net

 $
 2,421,314

 $
 2,711,877

 Operating Income (Loss)

 $
 (39,600
 )

 $
 388,412

 Adjusted Operating Income

 $
 562,573

 $
 670,104

 1
 Adjusted Operating Income (Loss) is a non-GAAP financial measure. See the “Non-GAAP Financial
Measures” section on page 58 for additional information, including our definition and our use of this non-GAAP financial measure, and for a reconciliation to its most comparable GAAP financial measure.
 The following table within ‘ Segment Results of Operations’ reflects proposed updates to remove the segment reference for
Corporate/Inter-segment Eliminations and clarify language for Selling, general, and administrative expenses to more clearly align with the ‘ Reconciliation of total segment adjusted operating income’ section of the segment footnote
table. Corporate / Inter-segment Eliminations
 The following table sets forth our Corporate / Inter-segment Eliminations results for the periods indicated.

 Years Ended December 31,

 Change

 (In thousands)

 2024

 2023

 2024 vs. 2023

 Revenues, net

 $
 (16,703
 )

 $
 (9,186
 )

 81.8
 %

 Technical and operating expenses (excluding depreciation and amortization) (a)

 (9,767
 )

 (11,934
 )

 (18.2
 )%

 Selling, general and administrative expenses
(b)

 114,975

 105,936

 8.5
 %

 $
 (121,911
 )

 $
 (103,188
 )

 18.1
 %

 (a)
 Technical and operating expenses excludes cloud computing amortization

 (b)
 Selling, general and administrative expenses excludes share-based compensation expenses and cloud computing
amortization, and are presented net of inter-segment eliminations Selling, general and administrative expenses
 Selling, general and administrative expenses consist of unallocated executive management and administrative support services, such as executive
salaries and benefits costs, costs of maintaining corporate headquarters, facilities and common support functions. Selling, general and administrative expenses increased primarily due to higher employee related costs, including higher allocated
overhead costs and compensation incurred in connection with an executive officer’s separation agreement.

 The ‘Non-GAAP Financial Measures’ table previously
reconciled Operating income to Adjusted operating income on a segment basis. The Company will amend its presentation to reconcile Income (loss) from operations before income taxes to Adjusted operating income on a consolidated basis, as proposed
below. Non-GAAP Financial Measures

 Year Ended December 31,

 (In thousands)

 2024

 2023

 Income (loss) from operations before income taxes

 $
 (174,497
 )

 $
 296,006

 Other income (expense):

 Interest expense

 (166,186
 )

 (152,703
 )

 Interest income

 36,803

 37,018

 Loss on extinguishment of debt, net

 (105
 )

 — 

 Miscellaneous, net

 (5,409
 )

 23,279

 Operating income (loss)

 (39,600
 )

 388,412

 Share-based compensation expenses

 26,051

 25,665

 Depreciation and amortization

 98,015

 107,402

 Impairment and other charges

 399,513

 96,689

 Restructuring and other related charges

 49,464

 27,787

 Cloud computing amortization

 13,452

 10,543

 Majority owned equity investees AOI

 15,678

 13,606

 Adjusted operating income (loss)

 $
 562,573

 $
 670,104

 3.
 Please revise future filings to reconcile the total of the reportable segments’ amount for each measure
of profit or loss to consolidated income before income taxes. Refer to ASC 280-10-50-30(b) and ASC
 280-10-50-28C. In this regard, the reconciliation should include a single amount for the subtotal of the reportable
segments’ measures of profit or loss with a reconciliation of that amount to consolidated income before income taxes. The segment note currently separates reconciling items among the reportable segments and Corporate / Inter-segment
eliminations category and results in the presentation of an additional non-GAAP measure of consolidated adjusted operating income.
 Company Response : In future filings, the Company will amend its presentation to include a reconciliation of segment adjusted operating
income to consolidated income before income taxes, as proposed in our response to Comment #2 above. In connection with our responses, we
acknowledge that we are responsible for the accuracy and adequacy of our disclosures, notwithstanding any review, comments, action or absence of action by the Staff.
 If you have any questions, please contact Michael Sherin, Chief Accounting Officer, at Michael.Sherin@amcnetworks.com or Patrick
O’Connell, Chief Financial Officer, at Patrick.OConnell@amcnetworks.com. Sincerely,
 /s/ Patrick O’Connell    
 Patrick O’Connell Executive
Vice President and Chief Financial Officer /s/ Michael J. Sherin III   
 Michael J. Sherin III Executive
Vice President and Chief Accounting Officer

 cc:   

 Kristin A. Dolan, Chief Executive Officer Sal
Romanello, Executive Vice President and General Counsel (AMC Networks Inc.)
 Robert W. Downes, Esq. (Sullivan & Cromwell LLP)
 Daniel Meagher
 (KPMG LLP)