SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 16, 2025

Trisha Gosser
Chief Financial Officer
Gannett Co., Inc.
175 Sully's Trail, Suite 203
Pittsford, NY 14534

 Re: Gannett Co., Inc.
 Form 10-K for the Year Ended December 31, 2024
 Form 10-Q for the Quarter Ended March 31, 2025
 Response Letter Dated June 27, 2025
 File No. 001-36097
Dear Trisha Gosser:

 We have reviewed your June 27, 2025 response to our comment letter 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.
Unless we note otherwise, any references to prior comments are to comments in
our June 12,
2025 letter.

Form 10-K for the Year Ended December 31, 2024
Note 14. Segment Reporting, page 119

1. We note from your response to our prior comment 2, that Adjusted EBITDA
is the
 single measure of segment profit or loss used by your CODM to assess
performance
 and allocate resources across your reportable segments. We also note
that you will
 remove your presentation of net income by segment beginning with your
next Form
 10-Q. Please tell us whether you also intend to revise your presentation
of segment
 information included in the Use of Non-GAAP Information section of your
quarterly
 earnings press releases.
 July 16, 2025
Page 2

2. We note from your response to our prior comment 5, that the corporate
and other
 column includes corporate-level administrative expenses and results
related to the
 runoff of a legacy business. We also note from your proposed disclosure
that you will
 present a corporate line item beneath the subtotal for Segment Adjusted
EBITDA, as
 part of your reconciliation of the total of the reportable segments
measures of profit
 or loss to your consolidated income before taxes. However, it is not
clear from your
 response, how you will revise your disclosure of the significant segment
expenses and
 other segment items. Please provide us with your proposed disclosure.
Refer to ASC
 280-10-50-26A and 50-26B.

3. We note from your response to our prior comment 6 that the amount
classified within
 Other in the Corporate and other column mostly includes
expenses that are
 allocated to the reportable segments as part of your internal reporting
process and
 related to categories such as payroll, benefits, outside services. You
disclose in
 footnote (a) to "Other" that other expenses include corporate
allocations of shared
 costs and equity loss (income) in unconsolidated investees, which are
not separately
 provided to your CODM. It appears there are amounts reflected in "Other"
for your
 reportable segments that exceed the $224 million of allocated expenses
and amounts
 reflected in your consolidated financial statements related to
unconsolidated
 investees. Please explain to us the nature of the additional amounts in
"Other" and tell
 us how you intend to revise your disclosure in footnote (a) or elsewhere
to describe
 the composition of other segment items as required by ASC 280-10-50-26B.
 Please contact Claire Erlanger at 202-551-3301 or Kevin Woody at
202-551-3629 if
you have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>