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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

May 30, 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 May 1, 2024 with additional Staff comments (“Comment Letter”) in
connection with (i) our response dated April 15, 2024, to the Staff’s letter dated March 18, 2024 and (ii) our prior 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 May 30, 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: You indicate “Other” is one of your reportable segments, and it consists of four operating segments and head
office functions. Your footnote disclosure refers to this segment as Other, Corporate and Eliminations. Please tell us whether you have aggregated these operating segments, and if so, provide us with your analysis supporting aggregation. If these
operating segments have not been aggregated, whether “Other” consists of information about other business activities and operating segments that are not reportable, and if so, why “Other” is disclosed as a reportable segment. See
ASC 280-10-50-11 through -15. Finally, please tell us whether, and if so why,
eliminations have been combined in “Other” rather than presented as part of reconciliations from total reportable segments’ amounts to consolidated totals. See ASC 280-10-50-30 and -31.

 Response No. 1: The Company respectfully acknowledges the Staff’s comment. To clarify,
“Other” (as historically presented) consists of the Company’s head office functions, eliminations and two operating segments: FOX Studio Lot and Credible Labs. The Company in total has four operating segments: Cable Network
Programming, Television, Credible Labs and FOX Studio Lot.

 The operating segments that are not separately reported (FOX Studio Lot and Credible Labs) do
not meet the quantitative threshold of 10% outlined in ASC 280-10-50-12, either individually or in the aggregate. These two
operating segments are not reportable segments, and the Company has historically combined information about these operating segments, head office functions and eliminations and reported these combined activities as “Other”. In all future
filings, beginning with the Company’s Annual Report on Form 10-K for the year ending June 30, 2024 (the “2024 10-K”), we will update the disclosures
to clarify that “Other” is not a reportable segment.

 We acknowledge the Staff’s comment with respect to the presentation of eliminations.
In all future filings, beginning with the 2024 10-K, and for comparable prior periods presented in such filings, the Company will break out eliminations separately and present such amounts as part of the
reconciliation from total reportable segments’ amounts to consolidated totals for all periods.

 Comment No. 2: You indicate
in your response to prior comment one that revenue targets are managed at the consolidated Company-wide and operating segment level. However, it appears that revenue and EBITDA targets are established in the budget for certain Business Units and
Business Components. Please describe budgeting process in more detail. Explain who approves the budget at each step of the process, including at the Business Unit and Business Component levels. Additionally, explain and how and why revenue and
EBITDA budgets are developed for Business Units and Business Components.

 Response No. 2: The Company respectfully acknowledges the Staff’s
comment.

 We believe that the Company’s reporting process, as further detailed below, provides the most useful and informed information to the chief
operating decision maker (“CODM”), the Board of Directors (the “Board”) and the market. Since revenue and a significant amount of costs (rights/talent/technology/IT) are determined on a consolidated basis at the CODM level, we
assess the most relevant and comparable method to report the Company’s operations both internally and externally with clarity for the users. It is important to note that our business unit leaders are primarily creative producers, who are
charged by the CODM with delivering the highest quality broadcast and cable television on-screen programming to their audiences. They have virtually no responsibility for any revenue generation, nor for much
of their cost base as these are both handled centrally and under the leadership of the CODM. Our determination of segments reflects the way in which we manage the business and considers the nature of our industry and the distinct differences between
broadcast and cable television. For example, note that in the case of broadcast television, advertising is sold centrally in a different fashion than for our Cable Network Programming segment in that advertisers make substantial annual contractual
commitments to purchase advertising on our Broadcast Network through an industry process called the “Upfront.” Cable Network Programming segment advertising is more dependent on uncontracted month to month centralized selling by our
centralized sales team. Another point of difference is that our Broadcast Network in our Television segment contracts with affiliated non-owned and operated station groups for a significant portion of its
affiliate revenues, while our Cable Network Programming segment contracts exclusively with distributors. The Television segment is also comprised of uniquely FCC licensed businesses that broadcast over the air and are distinctly different in
operation from our Cable Network Programming segment. These distinct characteristics highlight the differences in our businesses and are among the factors considered for our ongoing determination of segments. In fact, external users of our financial
statements look to the Cable Network Programming and Television segments’ reporting for the distinct and different trends in these two segments so they can accurately compare to other companies operating separately in each sector.

 2

 The budget is formally approved by the Board at a consolidated Company-wide level. Because of the
centralized nature of substantially all of the revenue and much of the cost components for the Company, there is no formal approval process for the revenue and EBITDA targets for the business units or business components by the segment manager, the
CODM or the Board. The below table describes who is responsible for establishing revenue and EBITDA targets included in the annual budget:

Responsibility 

 Targets Established

CODM1
 

 Consolidated Company and Cable Network Programming and Television operating segments
revenue and EBITDA

Functional Leaders2
 

 1.  Affiliate fees and advertising revenue for the Cable Network
Programming and Television operating segments

2.  Affiliate fees and advertising revenue for business units and business components, as applicable

 3.  Centralized cost center functions
supporting all of the Company’s commercial activities

Segment Manager3  

 1.  EBITDA for the Cable Network Programming and Television operating
segments delineated into the following:

 Business unit
EBITDA:

 ●   FOX News Media

●   FOX TV Stations

Business component EBITDA:

●   National Sports Cable Networks

●   FOX Broadcast Network (Sports)

●   FOX Broadcast Network (Entertainment)

●   Tubi AVOD service

2.  EBITDA and Revenue for Credible and FOX Studio Lot

 1 The CODM consists of the Company’s Executive
Chair and Chief Executive Officer, Chief Operating Officer, Chief Financial Officer and Chief Legal and Policy Officer.

 2 The functional leadership of affiliate fees and advertising revenues are the responsibility of the Company’s Chief Operating Officer and its President of Advertising Sales, Marketing and
Brand Partnerships.

 3 The Company’s Chief Operating Officer and Chief
Financial Officer together represent the segment manager for each operating segment.

 Our budgeting process starts with the CODM establishing revenue
and EBITDA targets at a consolidated Company-wide level and operating segment level. The principal focus when setting these targets, based on relative size to the consolidated Company, is on the Cable Network Programming and Television operating
segments. The discussion below therefore focuses on the budgeting process for these two operating segments. The budgeted financial information for Credible Labs and the FOX Studio Lot are separately determined and provided through discussions with
these operating segments and the segment manager.

 3

The business unit and business component EBITDA1 targets as discussed below are based on the outcome of the revenue targets established by the
functional leaders along with costs allocated to these businesses by the centrally managed cost centers. As a result, discussions between the segment manager and business unit leaders are primarily focused on annual creative objectives and
subsequently on a narrow scope of costs and ancillary revenues managed independently by the business unit leaders.

 As described in further detail in the
Company’s response letter dated April 15, 2024, the CODM separately meets with functional leaders of affiliate fees and advertising sales to determine anticipated annual revenue targets, which includes consideration of financial
information at the consolidated Company-wide level and the operating segment level for Cable Network Programming and Television. For advertising revenue, which is substantially centrally managed, the underlying assumptions and establishment of the
revenue targets for the budget are determined by the functional head of advertising sales and reflect the estimated price charged for each advertising unit, which is largely based on the size and demographics of the audience uniquely viewing our
Broadcast Network in our Television segment or Cable Network Programming segment and the number of advertising units available to be sold. Affiliate fee revenue is also centrally managed and includes revenues generated under agreements with
distributors and affiliated non-owned and operated station groups and reflects the unique revenue for our Television segment or Cable Network Programming segment that we expect to earn based on the number of
subscribers receiving the programming and a per subscriber fee and in the case of our Television segment, fixed programming fees from non-owned and operated station groups.

Once revenue targets are set by the functional leaders of affiliate fees and advertising sales and agreed to by the CODM at a consolidated Company-wide and
operating segment level for Cable Network Programming and Television, the revenue and centralized cost targets are then distributed by the functional leaders to the applicable business unit and business component level. Centralized costs reflect
business activities such as maintaining and enhancing the Company’s IT infrastructure and the workforce supporting the Company’s advertising sales and affiliate fees. Business unit leaders have absolutely no oversight of these matters and
do not attend the meetings between the CODM, the functional leaders of affiliate fees and advertising sales and centrally managed cost centers that establish these centralized revenue targets and centralized cost targets, and they also are not
involved in the revenue and centralized cost targets distributed by the functional leaders to the business units.

 Once the revenue and centralized cost
targets are set, the CODM establishes the EBITDA targets at the consolidated Company and operating segment levels. The segment manager then sets the EBITDA targets at the business unit and business component level as listed in the above table. These
targets are determined through strategy meetings with the segment manager and business unit leaders to discuss initiatives, operational and strategic plans, and the costs required to support the overall consolidated Company revenue and EBITDA
targets. Business component EBITDA targets not set by the segment manager are determined through discussions between the business unit and business component leaders based on targets established at the business unit level.

At the end of the annual budget process, the business unit leaders present their final budget to the CODM. The focus of these meetings is to discuss the on-screen initiatives and operational and strategic plans to support the overall consolidated Company revenue and EBITDA targets. In connection with these meetings, the CODM receives the underlying budget
submissions, which include financial information at a business unit and/or business component level to provide context to the CODM for these operational discussions described above. Also, the CODM does not have input in the business unit or business
component budgets and generally does not meet separately with the business component leaders.

1
 The EBITDA targets are calculated consistently with Segment EBITDA and/or Adjusted EBITDA, as applicable,
presented in our SEC filings.

 4

 At the conclusion of these meetings and presentations, the CODM makes the decision to furnish the
consolidated budget to the Board for approval. As described in further detail in the Company’s response letter dated April 15, 2024, the Board receives a summarized version of the Company’s annual budget. The material provided to the
Board includes non-financial information such as viewership and subscriber trends and financial information, including revenue and EBITDA targets for the Cable Network Programming and Television operating
segments. The Board also receives budgeted financial information for certain business units and business components deemed necessary to provide additional context or information on the operational themes underlying the operating segments.

The Company consistently includes a combination of revenue and EBITDA information for two business units and five business components in budget materials
provided to the Board, as outlined in the table below.

 Business Unit

 Financial Information

 Business
Component

 Financial Information Included for:

FOX News Media 

Included

Not Included

FOX Sports 

Not Included

 ●   National
Sports Cable Networks

 ●   FOX Broadcast Network (Sports)

FOX Entertainment 

Not Included

FOX Broadcast Network (Entertainment)

FOX Television Stations 

Included

Not Included

Tubi Media Group 

Not Included

 ●   Tubi AVOD
service

 ●   Credible Labs

Other 

Not Included

Not Included

 The business unit and business component information outlined in the table above is consistently developed and delivered to
the Board as the information is considered necessary to contextualize the operational themes underlying each operating segment. However, it is important to note that this budgeted financial information is included for reference only; it is not the
primary focus for the Board. Similar to the CODM, the Board focuses on revenues from advertising sales and affiliate fees and EBITDA at a consolidate