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United States securities and exchange commission logo
May 9, 2024
Charles H. R. Bracken
Chief Financial Officer
Liberty Global Ltd.
Clarendon House, 2 Church Street
Hamilton HM 11, Bermuda
Re:Liberty Global Ltd.
Form 10-K for the Year Ended December 31, 2023
Filed February 15, 2024
Form 8-K filed May 1, 2024
File No. 001-35961
Dear Charles H. R. Bracken:
            We have reviewed your filing and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Note 19. Segment Reporting , page II-116
1.We note that Central and Other is not listed as a reportable segment, rather it is defined as
a category and appears to include intercompany and corporate functions as well as a
business unit. As such, please tell us your consideration of the guidance in ASC 280-10-
50-1 through 50-5 for the identification of your operating segments and/or reportable
segments. Please note that if your Central and Other category is presented under ASC
280-10-50-15, it does not represent a reportable segment and should be excluded from the
reportable segment total.
2.We note the presentation of Total Adjusted EBITDA in the reconciliation on page II-119
does not appear to comply with ASC 280-10-50-30(b) as the inclusion of Adjusted
EBITDA for Central and Other in the total does not appear to represent the total of the
reportable segments' measure of profit or loss. As such, Total Adjusted EBITDA would
represent a non-GAAP measure which is specifically prohibited in your financial

 FirstName LastNameCharles H. R.  Bracken
 Comapany NameLiberty Global Ltd.
 May 9, 2024 Page 2
 FirstName LastName
Charles H. R.  Bracken
Liberty Global Ltd.
May 9, 2024
Page 2
statement footnotes by Item 10(e)(1)(ii)(c) of Regulation S-K. Furthermore, the total of
your reportable segments’ measure of profit or loss should be reconciled to consolidated
net income/(loss) before income taxes. Accordingly, please revise your presentation of
your reportable segments’ measure of profit or loss and the accompanying reconciliation
to comply with ASC 280-10-50-30(b). To this end, please reverse the order of the
reconciliation such that you start with the total of your segment measure of profit or loss
and reconcile to consolidated net income on a pre-tax basis.
Form 8-K filed May 1, 2024
Exhibit 99.1
Glossary, page 21
3.We refer to your measure of Adjusted EBITDA less P&E additions. It is not clear to us
how this measure provides any meaningful information for your investors. Please explain
and tell us how you considered Questions 100.01 and 100.04 of the non-GAAP
Compliance and Disclosure Interpretations.
4.We refer to your measure of Distributable Cash Flow. We note that the measure adjusts
for “Other affiliate dividends” which "are funded by activities outside of their normal
course of operations." As it appears this adjustment may have the effect of changing
recognition and measurement principles required to be applied under GAAP, please
explain in detail the nature of and reasons for this adjustment and why it does not result in
the presentation of an individually tailored measure pursuant to Question 100.04 of the
non-GAAP Compliance and Disclosure Interpretations.
            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.
            Please contact Joseph Cascarano at 202-551-3376 or Robert Littlepage at 202-551-3361
if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology