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April 13, 2023
Christopher Noyes
Chief Financial Officer
Liberty Latin America Ltd.
2 Church Street
Hamilton, Bermuda HM 11
Re:Liberty Latin America Ltd.
Form 10-K for the Year Ended December 31, 2022
Filed February 22, 2023
Form 8-K filed February 22, 2023
File No. 001-38335
Dear Christopher Noyes:
            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 the Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Year Ended December 31, 2022 as Compared with Year Ended December 31, 2021
Consolidated Adjusted OIBDA, page II-6
1.Your discussion and analysis of Consolidated Adjusted OIBDA absent corresponding
information on Consolidated Operating Income is not consistent with the guidance
prescribed in Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the C&DI on
Non-GAAP Financial Measures.  Please revise in future filings.

 FirstName LastNameChristopher  Noyes
 Comapany NameLiberty Latin America Ltd.
 April 13, 2023 Page 2
 FirstName LastName
Christopher  Noyes
Liberty Latin America Ltd.
April 13, 2023
Page 2
Form 8-K filed February 22, 2023
Non-GAAP Reconciliations
Adjusted OIBDA and Adjusted OIBDA less P&E Additions, page 22
2.We note your calculation of Adjusted OIBDA less Property and Equipment
Additions results in a measure of income reflecting an adjustment for a balance sheet
component (i.e., asset addition).  Tell us how your calculation of this performance
measure is consistent with performance measurement principles required to be applied in
accordance with GAAP.  Refer to Question 100.04 of the C&DI on Non-GAAP measures.
Non-GAAP Reconciliation for Consolidated Leverage Ratios, page 29
3.Please explain to us why you annualize operating income and Adjusted OIBDA based on
the last two quarters instead of actual operating income and Adjusted OIBDA during the
trailing twelve months in connection with calculating the denominator of leverage ratios
on a GAAP and non-GAAP basis. Given historical monthly and annual data, it is unclear
why GAAP and non-GAAP performance measures for an annual period have to be
estimated ("annualized")  and how "the last two quarters annualized" would be a faithful
representation of an annual period.
            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 Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert
Littlepage, Accountant Branch Chief at (202) 551-3361 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Brian Zook