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CORRESP

 Steven Tomsic

 Chief Financial Officer

 Fox Corporation

1211 Avenue of the Americas

 New York, New York 10036

 CORRESPONDENCE FILED VIA EDGAR

April 15, 2024

 Securities and Exchange Commission

Division of Corporation Finance

 Office of Technology

100 F Street, NE

 Washington, DC 20549

Attn: Inessa Kessman and Robert Littlepage

Re:
 Fox Corporation

 
 Form 10-K for the Fiscal Year Ended June 30, 2023

 
 File No. 001-38776

Ladies and Gentlemen:

 We are submitting this
letter in response to comments from the staff of the Securities and Exchange Commission (the “SEC” or the “Staff”). We received your letter dated March 18, 2024 with additional Staff comments (“Comment Letter”) in
connection with our response dated March 8, 2024, to the Staff’s original letter dated February 27, 2024 regarding Fox Corporation’s (the “Company”, “FOX”, “we” or “our”) Annual Report on
Form 10-K for the fiscal year ended June 30, 2023 (the “2023 10-K”). The Staff agreed to our request for an extension until April 15, 2024. The
headings and numbered paragraphs of this letter correspond to the headings and paragraph numbers contained in the Comment Letter. For ease of review, we have reproduced the text of the Comment Letter in boldfaced print below, followed by the
Company’s response to each comment.

 Form 10-K for the Fiscal Year Ended June 30, 2023

Notes to the Consolidated Financial Statements

Note 17. Segment Information, page 101

Comment No. 1: We note your response to our prior comment two which indicates the financial information reviewed by the CODM contains
income statement results for Cable Network Programming, Television, FOX Studio Lot and Credible. Please describe any other disaggregated financial information the CODM receives, the frequency it is provided, and how it is used by the CODM. In your
response, specifically tell us what financial information the CODM receives about the business units, if any. Finally, tell us what disaggregated financial information is provided to the Board of Directors.

Response No. 1: The Company respectfully acknowledges the Staff’s comment.

 Background

As described in greater detail in the Company’s response letter dated March 8, 2024, the Company operates in three reportable segments: Cable Network
Programming, Television and Other, within which it has four operating segments and head office functions. Decisions about allocating resources to and assessing the performance of each of the Company’s operating segments are made by Fox
Corporation’s Executive Officers (the “Executive Officers”), comprising the Executive Chair and Chief Executive Officer, Chief Operating Officer, Chief Financial Officer, and Chief Legal and Policy Officer. Thus, the Executive
Officers collectively are the chief operating decision maker (“CODM”) for the Company.

 The CODM is responsible for assessing the performance of
and allocating resources to the operating segments. Key operating decisions center around the delivery of content that drives revenue from two key sources: advertising and affiliate fees. Advertising revenue reflects the price charged for each
advertising unit sold and affiliate fees includes multi-year distribution agreements with multichannel video programming distributors (“MVPDs”) and fees from affiliated non-owned broadcast stations.
While each of our Cable Network Programming and Television reportable segments have revenues from multiple sources, as noted in our prior response, the predominant source of revenue in our Cable Network Programming segment relates to affiliate fees,
and the predominant source of revenue in our Television segment relates to advertising revenues. In making key operating decisions, the CODM focuses on actions that will support growth in these primary revenue streams, recognizing that many elements
of income are generated on a Company-wide or an operating segment basis. For example, we market our portfolio of networks to distributors at the Company level in a single negotiation for our Cable Network Programming segment as well as to affiliated
non-owned and operated station groups for our Television segment. As another example, we acquire multiyear sports rights at the Company level for events to be aired across our Cable Network Programming segment
and/or our Television segment. As a final example, we market advertising opportunities at the Company level across our entire portfolio of networks and programming.

In addition to these key operating decisions noted above, the CODM is also responsible for broader strategic decisions, including entering into mergers,
acquisitions, and partnerships, and expanding into new and/or different geographic areas and lines of business.

 When making resource allocation
decisions, the CODM evaluates how the investment will impact affiliate fees and advertising revenues for the Company. This includes consideration of several financial factors, including primarily the costs associated with any new content, as well as
non-financial factors, including viewership, subscribers across distributors, relationships with advertisers, advertising trends, relationships with affiliated non-owned
and operated station groups, and others. While information provided to the CODM includes statistics such as viewership/subscribers at a business unit or business component level (as discussed more fully below), the CODM is generally not involved in
making decisions with respect to specific on-screen programming.

 Information Provided to CODM

Monthly, the CODM receives a reporting package that includes financial information on a consolidated Company-wide basis and for each operating segment
detailing revenue and the Company’s measure of segment profitability, which we refer to as Segment and/or Adjusted EBITDA in our SEC filings (collectively referred to in this response letter as “EBITDA”). In addition, the monthly
reporting package includes supplemental details for certain, but not all, business units, and also for certain, but not all, of the Company’s business components, which is a level of activity beneath a business unit and, of which there are more
than 20, but may change over time. We have included tables below that are intended to assist in understanding FOX’s business units and business components and how they fit into the overall structure of the Company.

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 The table below sets out a simplified structure of the internal reporting for FOX of the business units and
how they align with the operating and reportable segments of the Company:

 The table below sets out additional information about the Company’s business components and how they align with the
reportable segments and business units described in the table above:

 As noted, the predominant revenue source for the Cable Network Programming segment is affiliate fees and the predominant
revenue source for the Television segment is advertising revenue. Functional leadership of affiliate fees and advertising revenues, which represent approximately 90 percent of the Company’s total revenue, are the responsibility of the
Company’s Chief Operating Officer and its President of Advertising Sales, Marketing and Brand Partnerships. Therefore, the management of nearly all of the Company’s revenue does not sit with any of the business unit leaders.

 3

 As described in the Company’s response letter dated March 8, 2024, there are separate business
unit leaders who focus on operating activities such as programming and production activities within the Company’s Cable Network Programming and Television segments. Naturally, business unit results are significantly impacted by revenues.
However, as discussed above, there are separate leaders focused on distribution and advertising monetization opportunities, and the revenues are managed separately on a company-wide or operating segment basis and not at a business unit level. The
leaders of these revenue functions report directly to members of the CODM. As such, the Company has determined that the business unit leaders are not segment managers as they do not manage or own the business unit from
end-to-end. Business unit leaders are predominantly responsible for the creative activities of their linear and digital networks as it relates to all facets of
programming delivered to our viewers.

 The CODM receives financial information in connection with the Company’s (1) reporting of monthly,
quarterly, and annual financial performance and (2) annual budget.

 Monthly Reporting – The monthly reporting package to
the CODM includes financial information consisting of revenue, expense, and EBITDA. Similar information is provided for the quarterly and annual financial performance to the CODM. Financial information included in the reporting package is
compared to both prior year and budget on a year-to-date and quarterly basis, as applicable. The table below represents the level within the Company’s
organizational structure that revenue and EBITDA financial information is detailed in the monthly reporting package.

1
 FOX Sports, FOX Entertainment and FOX Television Stations’ affiliate revenues are derived from
allocations. In addition, certain content costs are allocated across business units as a result of content being delivered on multiple platforms.

2
 Not all components are presented, and the specific components presented may vary each period.

3
 N/A indicates that information is not included in the monthly reporting package.

 4

 Annual Budget - The table below represents the information included in the annual
budget to the CODM. Budget information included in the report is compared to prior year’s actuals.

4
 Not all components are presented, and the specific components presented may vary each period. Also, the
components presented may not be the same as the components presented in the Monthly Reporting.

5
 N/A indicates that information is not included in the budget.

As illustrated above, financial information included in the reporting packages provided to the CODM includes revenue and EBITDA for the operating segments and
certain business units. For certain business units, including FOX Sports, FOX Entertainment and Tubi Media Group, financial information is provided solely on a disaggregated business component level basis (i.e., information for these business units
is not included in the reporting packages on a business unit level). The financial information referenced above is provided to the CODM on a monthly basis and is accompanied by a monthly meeting involving the members of the CODM. That meeting serves
as the primary basis for assessing performance and, together with the budgeting process, for allocating resources. In that meeting, the Chief Executive Officer and Chief Financial Officer present the results from the month, focused primarily on
consolidated Company-wide results (consolidated revenue, advertising revenue, affiliate fees, and EBITDA). However, the meeting also includes a discussion of operating segment level revenue and EBITDA. The discussion focuses on revenue trends,
including status of key distributor and advertising relationships, as well as a discussion of trends relating to subscribers and viewership. While the business unit leaders are present in that meeting, they do not present on their respective
business unit EBITDA results. Rather, the business unit leaders may be asked to provide information on specific key topical creative programming matters, which vary over time. For example, during the Fall, business unit leaders may be asked to
discuss the football schedule or election coverage. Importantly, no participants at the meeting present on revenue at a business unit level, nor is there discussion about EBITDA at the business unit or component level. As a result, we believe that
while the reporting package includes information on revenue and EBITDA for certain business units (i.e., the information is regularly provided to the CODM), that information is not regularly reviewed by the CODM to assess performance or allocate
resources. Rather, the disaggregated financial information is provided to the CODM to enable them to respond to questions from the FOX Board of Directors, investors and other stakeholders about market trends impacting FOX.

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 As noted, the CODM also receives financial information in connection with the annual budgeting process, and
that information includes consolidated Company-wide, operating segment, business unit and, for certain businesses, component levels of disaggregation. To further contextualize the financial information presented in the annual budget, the CODM also
receives the underlying budget submissions from the individual business components.

 When setting the annual budget, the CODM separately meets with
functional leaders of affiliate fees and advertising sales to determine anticipated annual revenue targets, which includes a consideration of financial information at the consolidated Company-wide level and operating segment level. Affiliate fees
targets are established centrally considering market analyst reports, data from the existing affiliate group, existing agreements, and upcoming renewals. Advertising revenue targets are established centrally considering existing advertising rates
and expected advertising market conditions, along with the quality of programming and the expected viewership it will generate. Once revenue targets are established, the CODM then meets with business unit leaders to consider various initiatives and
discuss operational and strategic plans to support the overall total revenue targets and costs required to support these objectives. However, it is important to note that these discussions do not involve any conversation regarding revenue targets
for the business units given that those targets are managed at the consolidated Company-wide and operating segment levels.

 Information Provided to
Board

 Management provides the Board of Directors (the “Board”) financial information in connection with the Company’s (1) annual
budget and (2) the reporting of quarterly and annual financial information.

 For the annual budget, the Board receives a summarized version of the
Company’s annual budget in the same format as the CODM as described above. The Board does not receive the underlying budget submissions described above.

Financial information is provided to the Board in connection with the Company’s reporting of financial data to the SEC in the Company’s quarterly
and annual filings on Forms 10-Q and 10-K. Also, financial information is presented to the Board quarterly which includes EBITDA for certain business units (FOX News
Media and FOX Television Stations) and in specific cases, business components with clearly delineated subtotals for the operating segments. Financial performance included in this information is compared to both prior year and budget on a year-to-date and quarterly basis, as applicable. Consistent with the CODM, the Board focuses on revenues from advertising and affiliate fees at a consolidated Company-wide
level, as well as an operating segment level when approving the annual budget.

 Conclusion

The CODM evaluates the following financial information to make the key operating decisions for FOX’s business:

•

 Revenue and EBITDA at a consolidated Company-wide level

•

 Revenue for Cable Network Programming as a whole (predominantly affiliate fees, as well as some advertising
revenue) and EBITDA

•

 Revenue for Television as a whole (predominantly advertising revenue, as well as affiliate fees) and EBITDA

•

 Total revenue from advertisers

•

 Total revenue from affiliate fees

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 Furthermore, the non-financial information that is important to the
CODM’s decisions includes metrics that directly impact the Company’s revenue such as viewership, advertising rates, subscriber numbers and affiliate rates per subscriber. The operating segments are in alignme