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CORRESP
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CORRESP

 April 11, 2023

Division of Corporation Finance

 Office of Trade &
Services

 Securities and Exchange Commission

 100 F Street,
N.E.

 Washington, D.C. 20549-9303

 Attention:
Keira Nakada

      Rufus Decker

Re:
 Madison Square Garden Sports Corp.

Form 10-K for the Fiscal Year Ended June 30, 2022

Filed August 18, 2022

Form 10-Q for the Fiscal Quarter Ended December 31, 2022

Filed February 7, 2023

File No. 001-36900

Ladies and Gentlemen:

 This letter responds to
the comment letter (the “Comment Letter”) from the Staff of the Securities and Exchange Commission (the “Commission”), dated March 29, 2023, concerning the Annual Report on Form 10-K
for Fiscal Year Ended June 30, 2022 (the “Form 10-K”) and Quarterly Report on Form 10-Q for the Quarterly Period Ended December 31, 2022 (the “Form 10-Q) of Madison Square Garden Sports Corp. (“the Company”).

 For your convenience, we have
set forth the comments from your letter in bold immediately followed by the applicable responses. Unless otherwise indicated, capitalized terms used herein have the meanings set forth in the Form 10-K or Form 10-Q, and references herein to page numbers and section headings refer to page numbers and section headings in the Form 10-K or Form
10-Q, as noted.

 Form 10-K for Fiscal Year Ended
June 30, 2022

 Adjusted Operating Income (Loss), page 35

1.
 Please tell us how you determined that removing the effects of deferred rent in arriving at adjusted
operating income does not substitute individually-tailored recognition and measurement methods for GAAP. Alternatively, no longer include this adjustment. Refer to Question 100.04 of the Non-GAAP Financial
Measures Compliance and Disclosure Interpretations.

 Company Response: In response to the Staff’s comment
regarding removing deferred rent in arriving at adjusted operating income (“AOI”), we respectfully provide the following information for the supplemental information of the Staff:

The deferred rent amount removed in arriving at AOI relates to the arena license agreements (the “Arena License
Agreements”) with Madison Square Garden Entertainment Corp. (“MSG Entertainment”), which include fees charged by MSG Entertainment for the use of The Madison Square Garden Arena (“The Garden”) by the Knicks and Rangers (the
“Teams”) and include the terms outlining the fees paid by each Team to MSG Entertainment during such use as well as the services to

be provided by The Garden during the Teams’ periods of use and any revenue sharing provisions related to these services. The Arena License Agreements were executed in April 2020, have 35-year terms and stipulate an initial annual license fee in the first year, which then increases by 3% in each subsequent year. The Arena License Agreements were deemed to contain an operating lease under Financial
Accounting Standards Board Accounting Standards Codification (“FASB ASC”) Topic 842, Leases (“ASC 842”) (with the Company as a lessee), which requires operating lease costs from the lease component to be recognized on a
straight-line basis, including the 3% fixed annual increase, over the 35-year term. The non-cash portion of arena license fees charged by MSG Entertainment consist of
the difference between the straight-line lease expense recognized under ASC 842 for the respective year and the cash paid throughout the year in twelve equal installments.

In response to the Staff’s comment, the Company proposes to include a footnote appearing below the AOI reconciliation
table in its future filings that will describe this adjustment as follows:

•

 “This adjustment represents the non-cash portion of operating lease
costs related to the Company’s Arena License Agreements with MSG Entertainment. Pursuant to GAAP, recognition of operating lease costs is recorded on a straight-line basis over the term of the agreement based upon the value of total future
payments under the arrangement. As a result, operating lease costs is comprised of a contractual cash component plus or minus a non-cash component for each period presented. Operating income on a GAAP basis
includes operating lease costs of (i) $[XX] of expense paid in cash and (ii) a non-cash portion of $[XX] for the year ended June 30, 20XX, respectively.”

The Company has considered the guidance denoted in Question 100.04 of the Non-GAAP
Financial Measures Compliance and Disclosure Interpretations (“C&DI”), SEC Regulation S-K Item 10(e), and Regulation G, and respectfully advises the Staff that it believes that this adjustment is
not inconsistent with the non-GAAP disclosure framework for the reasons discussed herein. The Company believes that the inclusion in AOI of an adjustment for non-cash
operating lease costs assists management, investors, and analysts in assessing the performance of the Company in a manner consistent with the contractual arrangement in place with MSG Entertainment. The Company respectfully advises the Staff that,
for the reasons described in more detail below, it believes that supplementally presenting the non-cash portion of operating lease costs as an adjustment to AOI is useful to investors in evaluating the
Company’s performance on a period-to-period basis.

As noted above, the Company is the lessee in 35-year Arena License Agreements with MSG
Entertainment. These agreements contain an escalation clause that results in higher cash operating lease costs in the later periods of the term as opposed to at inception; however, the associated operating lease cost is recognized in the
Company’s statements of operations based on a straight-line calculation over the life of the agreements. Accordingly, adjustments for non-cash operating lease costs increase AOI in the earlier years of
these agreements. In the later years of these agreements, the trend reverses, and cash operating lease costs will exceed straight-line operating lease costs. Management will present this adjustment consistently for all periods regardless of whether
it is beneficial to AOI or not, which we believe complies with C&DI Question 100.02.

 The long-term nature of the Arena
License Agreements creates a material item for investors to understand when relying upon the Company’s financial statements. Management has historically used AOI, inclusive of the adjustment related to the
non-cash portion of arena license fees, when assessing the Company’s performance. Therefore, if the Company does not apply an adjustment to reflect the non-cash
component of operating lease costs, investors could be left with a suboptimal picture of the business’ ability to generate income in excess of cash operating costs. Although the straight-line recognition under ASC 842 reduces variability in the
amount of operating lease costs over the term of the Arena License Agreements, the Company understands that investors focus on the Company’s actual economic operating lease costs over a shorter period of time, such as one or more reporting
periods as an incremental data point to the presentation required by ASC 842.

 2

 The Company believes that AOI, which is a measure of the Company’s
ongoing core operating performance, supplements the investors’ understanding of its operating performance by excluding the non-cash portion of operating lease cost, which is not indicative of the
Company’s actual operating lease expense structure as it exists over such reporting period being evaluated by investors. The Company believes that the inclusion in the AOI calculation of the amount and direction of the adjustment for the non-cash portion of operating lease costs in each period will not be used in isolation by investors, but rather will supplement the Company’s financial statement disclosures and management’s discussion and
analysis of financial condition and results of operations.

 Finally, the Company believes that providing this incremental
disclosure will also be helpful to investors in future years. When the adjustment to AOI turns neutral or negative, investors will have a more complete understanding of the inflationary impact associated with contractual increases in operating lease
costs. This supplemental information will enhance investors’ ability to evaluate the Company’s recognition of expense in an amount that may be more or less than actual cash paid.

While management notes that the long-term nature of these agreements creates a noteworthy and important data point for the
relevance of the above-described adjustment, the Company also considered several other relevant pieces of guidance which we believe support the presentation in the Company’s AOI reconciliation. Please refer to the below list for further
details:

•

 As disclosed in the Company’s most recent annual meeting proxy statement, senior management of the company
is compensated based upon a ratio that includes, and weights materially, AOI performance (inclusive of the adjustment related to the non-cash portion of arena license fees) of the Company on a consolidated
basis. Management considered the guidance of SEC Regulation S-K Item 402, Instruction 5 when evaluating the non-cash portion of arena license fees adjustment.

•

 “Disclosure of target levels that are non-GAAP financial measures
will not be subject to Regulation G and Item 10(e) of Regulation S-K; however, disclosure must be provided as to how the number is calculated from the registrant’s audited financial statements.”

•

 Management respectfully notes that removing the effects of deferred rent in arriving at AOI is consistent with
how MSG Entertainment, the Company’s counterparty to the Arena Lease Agreements, determines its AOI.

 3

 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations

 Selling, General and Administrative Expenses, page 35

2.
 Please separately quantify each of the factors attributable to the increase in the selling, general and
administrative expenses. In addition, discuss the underlying reasons for the increases in these factors and, in light of the increase in your operating activities as demonstrated by the increases in revenues and direct operating expenses, explain
why the rate of increase in selling, general and administrative expenses was substantially less. Refer to Item 303 of Regulation S-K.

Company Response: In response to the Staff’s comment, in future filings, the Company will revise the disclosure and will separately
quantify each of the factors attributable to the increase/decrease in the selling, general and administrative expenses, including the underlying reasons for such increases and/or decreases. The information provided below reflects an updated sample
disclosure showing what the Company plans to disclose in future filings and reflects discussion of the increase in the selling, general and administrative expenses for the year ended June 30, 2022, as compared to the year ended June 30,
2021.

 Selling, general and administrative expenses primarily consist of (i) administrative costs, including
compensation, professional fees, costs under the Company’s services agreement with MSG Entertainment, (ii) fees related to the Company’s sponsorship sales and service representation agreements, and (iii) sales and marketing
costs. Selling, general and administrative expenses generally do not fluctuate in line with changes in the Company’s revenues and direct operating expenses given these expenses are largely contractual or fixed nature, except for certain
expenses described below.

 Selling, general and administrative expenses for the year ended June 30, 2022 increased
$22,968, or 11%, to $229,668 as compared to the prior year primarily due to (i) higher marketing costs of $8,217 primarily as a result of the shortened NBA and NHL 2020-21 regular season schedules in the
prior year, as well as the elimination of government mandated assembly restrictions at The Garden that were in place during the prior year, (ii) higher playoff related expenses of $4,632 primarily due to the Rangers playing ten home playoff
games in the current year as compared to the Knicks playing three home playoff games in the prior year, (iii) higher fees related to the Company’s sponsorship sales and service representation agreements with MSG Entertainment of $3,750, as
a result of the shortened NBA and NHL 2020-21 regular season schedules in the prior year, as well as the elimination of government mandated assembly restrictions at The Garden that were in place during the
prior year, (iv) higher costs related to the Company’s services agreement with MSG Entertainment of $2,211 and (v) higher other general and administrative expenses. These increases were partially offset by lower employee compensation
and related benefits, of $2,636, including the absence of severance related to team executives incurred in the prior year. As noted above, the Company’s selling, general and administrative expenses generally do not fluctuate in line with
changes in the Company’s revenues and direct operating expenses. This trend was more evident during the fiscal year ended June 30, 2022, as compared to the prior year, with the rate of increase in selling, general and administrative
expenses being substantially less than the increases in revenues and direct operating expenses which were primarily driven by the shortened NBA and NHL 2020-21 regular season schedules in the prior year, as
well as due to the elimination of government mandated assembly restrictions at The Garden that were in place during the prior year.

 Liquidity and
Capital Resources

 Cash Flow Discussion, page 38

3.
 Your presentation of the subtotal of net income (loss) and adjustments to reconcile net income (loss) to net
cash provided by (used in) operating activities appears to be a non-GAAP measure. Please either remove this subtotal or provide the disclosures required by Item 10(e) of Regulation S-K.

 Company Response: In the response to the Staff’s comment, the
Company respectfully advises that, in its most recently filed Form 10-Q for the fiscal quarter ended December 31, 2022, the Company eliminated the subtotal of net income (loss) and adjustments to
reconcile net income (loss) to net cash provided by (used in) operating activities. The Company further advises the Staff that it will not include the subtotal of net income (loss) and adjustments to reconcile net income (loss) to net cash provided
by (used in) operating activities in future filings.

 4

 Operating Activities, page 38

4.
 Please revise your analysis of cash flow changes to explain the business reasons for material changes
between periods in your operating cash flows. For example, discuss the underlying business reasons for material changes in each of these line items between periods:

•

 Accounts receivable, net,

•

 Net related parties receivables,

•

 Prepaid expenses and other assets,

•

 Accrued and other liabilities and

•

 Deferred revenue.

Refer to Item 303(b) of Regulation S-K.

Company Response: In response to the Staff’s comment, in future filings, the Company will revise the disclosure to provide
additional information for the business reasons for material changes between periods in the Company’s operating cash flows. The information provided below reflects an updated sample disclosure showing what the Company plans to disclose in
future filings.

 Operating Activities

Net cash provided by operating activities for the year ended June 30, 2022 was $178,056 as compared to net cash used in
operating activities in the prior year of $35,326. This was primarily due to the increase in net income adjusted for non-cash items and, to a lesser extent, changes in working capital assets and liabilities
driven by the COVID-19 pandemic in the prior year. The changes in working capital assets and liabilities were primarily driven by (i) a decrease in Accounts receivable, net of $93,576 primarily as a
result of the collection of league related receivables, includ