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April 11, 2023
Neil Watanabe
Chief Financial Officer
Loop Media, Inc.
700 N. Central Ave, Suite 430
Glendale, CA 91203
Re:Loop Media, Inc.
Form 10-K for Fiscal Year Ended September 30, 2022
Filed December 20, 2022
File No. 001-41508
Dear Neil Watanabe:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended September 30, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations.
Consolidated Results of Operations , page 57
1.You state your fiscal 2022 revenues increased $25,763,647 from the prior year and you
cite the increase was primarily due to three factors.  Although the listing of the factors
may be in order of their impact, please quantify cited factors so investors may understand
the magnitude of each.  Refer to section 501.04 of our Codification of Financial Reporting
Policies for guidance.

 FirstName LastNameNeil  Watanabe
 Comapany NameLoop Media, Inc.
 April 11, 2023 Page 2
 FirstName LastName
Neil  Watanabe
Loop Media, Inc.
April 11, 2023
Page 2
Liquidity and Capital Resources
Cash Flows ...
Net Cash Flow from [Used in] Operating Activities, page 61
2.We note you have a history of reporting negative operating cash flows, including for the
interim period ended December 31, 2022.  Please disclose in your periodic reports
the operational reasons for this condition when it exists and explain how you intend to
meet your cash requirements and maintain operations.  Also address whether this is a
known trend and provide related disclosures.  Refer to Item 303 of Regulation S-K and
Release Nos. 33-6835 and 33-8350 for guidance.
Index to Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Revenue Recognition , page F-13
3.We note you distribute your content and advertising primarily through your owned and
operated ("O&O") platform and through screens on digital platforms owned and operated
by third parties referred to as Partner Platforms.  Please explain to us and disclose in
further detail how you earn and recognize revenue and cost of revenue under each
arrangement.  In particular, we note your cost of revenue for advertising sales on your
partner platforms business is higher than your cost of revenue for advertising sales on
your O&O platform due to your significant revenue share with partner platform clients.
Explain to us and disclose the material terms and conditions of the revenue share
arrangements and the reason for the significant revenue share.  Explain to us and disclose
why the amount of the revenue share is not netted against the revenue you recognize and
the basis for your accounting.  Additionally, you state you are able to share typical
transaction costs associated with related programmatic advertising sales and server costs
with such clients.  Explain to us and disclose what this means and your accounting for
this, especially how the amount to share is determined.

            In closing, 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.
            You may contact Aamira Chaudhry at 202-551-3389 or Doug Jones at 202-551-
3309 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services