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January 18, 2023
Renee L. Wilm
Chief Legal Officer & Chief Administrative Officer
Atlanta Braves Holdings, Inc.
12300 Liberty Boulevard
Englewood, Colorado 80112
Re:Atlanta Braves Holdings, Inc.
Registration Statement on Form S-4
Filed December 21, 2022
File No. 333-268922
Dear Renee L. Wilm:
            We have reviewed your registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-4 filed December 21, 2022
Questions and Answers, page 15
1.We note Mr. Malone’s potential significant influence in your company following the split-
off.  In connection therewith:

•Please disclose, as you do on page 43, Mr. Malone's expected percentage of voting
power of SplitCo and discuss his significant and perhaps controlling influence over
corporate actions. Make conforming changes as appropriate to your risk factor on
page 43.

•As Mr. Malone will not be required to keep his aggregate voting power in SplitCo
under 49% according to your disclosure on page 43, please disclose the specific

 FirstName LastNameRenee L. Wilm
 Comapany NameAtlanta Braves Holdings, Inc.
 January 18, 2023 Page 2
 FirstName LastName
Renee L. Wilm
Atlanta Braves Holdings, Inc.
January 18, 2023
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percentage of outstanding shares that Mr. Malone would need to hold to control
general matters submitted to shareholders for approval, pursuant to which holders of
shares of New BATRA and New BATRB would vote together as a class.

•If you could be considered a “controlled company” under your applicable exchange
listing standards, please disclose so and discuss whether you will utilize any related
exemptions to governance rules and provide related risk factor disclosure, if
necessary.
2.We note that the split-off proposal contemplates the redemption by Liberty Media of each
outstanding share of BATRA, BATRB and BATRK “in exchange for one share of the
corresponding series of common stock of” SplitCo.  Here and in your sections entitled
“Summary” and “Risk Factors,” please prominently describe the number of votes per
share to which each series is entitled, as well as the circumstances or events in which the
conversion of the various series of shares are mandatory or optional, including any
exceptions.  Additionally, in your risk factor discussion, please:

•Disclose the risks that your multi-class capital structure may render your shares
ineligible for inclusion in certain stock market indices, and thus adversely affect share
price and liquidity.

•Disclose that future issuances of New BATRB shares may be dilutive to the holders
of New BATRA, particularly with respect to their voting power.
Summary, page 34
3.We note your reference to the “Risk Factors” starting on page 39.  Please also include a
summary of your risk factors relating to the split-off transaction in accordance with Item
503 and 105(b) of Regulation S-K.
Risk Factors
"The risk of injuries to key or popular players creates uncertainty and could negatively impact
financial results.", page 44
4.We note your disclosure that a “significant portion of the financial results of SplitCo will
be dependent upon the on-field success of the Braves.”  We also note the long-term
employment contract commitments outstanding as of September 30, 2022 in the amount
of $912.4 million, $244.0 million of which is due after 2026, as well as your disclosure on
page F-59 that $212 million of these obligations could extend through 2032.  In addition
to injury-related risks associated with your key or popular players that are discussed here,
please expand your discussion to also discuss the long-term valuation and commitment
risks associated with entering into such contracts, with a view towards providing
shareholders with a balanced picture of the risks that may impact your financial results.

 FirstName LastNameRenee L. Wilm
 Comapany NameAtlanta Braves Holdings, Inc.
 January 18, 2023 Page 3
 FirstName LastName
Renee L. Wilm
Atlanta Braves Holdings, Inc.
January 18, 2023
Page 3
"Broadcasting rights, both national and local, present an important source of revenue for SplitCo
. . . ", page 46
5.We note your disclosure that “Braves Holdings derives revenue directly from the sale of
their local broadcasting rights through an individually negotiated carriage or license
agreement” and that a “majority of this revenue is reliant on a limited number of
broadcasting partners,” as well as your disclosure on page 129 that such revenue related to
local broadcasting rights is “substantial” in nature.  Please tell us whether you
substantially depend on any broadcasting and/or sponsorship relationships (e.g., your
agreement with Sportsouth Network II, LLC), and to the extent that you do, please file
any associated agreements as an exhibit to the registration statement, and include a
discussion of the material terms of the agreements in your proxy statement/prospectus.
Please see Item 601(b)(10)(ii)(B) of Regulation S-K.
"Weak economic conditions may reduce consumer demand for products, services and events
offered by SplitCo.", page 49
6.Here or elsewhere, as appropriate, please discuss the risk that “inflation and any
recession” may impact your mixed-use development business segment.  In connection
therewith, in your section entitled “SplitCo Management’s Discussion and Analysis of
Financial Condition and Results of Operations,” please address the extent that your
operations have been materially impacted by recent inflationary pressures.
Factors Relating to Ownership of SplitCo's Common Stock and the Securities Market, page 50
7.We note your disclosure on page 195 that “the Eighth Judicial District Court of Clark
County, Nevada, shall, to the fullest extent permitted by law, be the exclusive forum for
certain specified types of actions, including . . . certain actions asserting claims under the
laws of the United States that may be brought in either a federal forum or a forum in
Nevada.”  Please include a risk factor disclosing whether this provision applies to actions
arising under the Securities Act or Exchange Act.  In this regard, we note that Section 22
of the Securities Act creates concurrent jurisdiction for federal and state courts over all
suits brought to enforce any duty or liability created by the Securities Act or the rules and
regulations thereunder and Section 27 of the Exchange Act of 1934 provides that the
federal courts have exclusive jurisdiction of Exchange Act claims.  If the provision applies
to Securities Act claims, please also revise your proxy statement/prospectus to state that
there is uncertainty as to whether a court would enforce such provision.  Please also
ensure that the exclusive forum provision in your restated charter is consistent with your
revised disclosure.
"The SplitCo restated charter includes restrictions on the share ownership of SplitCo common
stock by certain persons . . . ", page 53
8.We note your disclosure that the SplitCo restated charter will provide that “no person may
own 10% or more of the number of outstanding shares of SplitCo common stock unless,

 FirstName LastNameRenee L. Wilm
 Comapany NameAtlanta Braves Holdings, Inc.
 January 18, 2023 Page 4
 FirstName LastNameRenee L. Wilm
Atlanta Braves Holdings, Inc.
January 18, 2023
Page 4
in the case of this clause (iii), such person is expressly approved by MLB or qualifies as
an exempt person (which is generally defined to include [ ]).”  Please revise to clarify that
“Liberty Media would also be an exempt person,” as you disclose on page 23.  Here or
elsewhere, as applicable, also revise to clarify whether the agreement between Liberty
Media and Major League Baseball has been or is being revised to reflect new ownership
limitation terms in SplitCo, and to the extent that there is an executed agreement, please
summarize and file such agreement as an exhibit to the registration statement.
The Proposed Transactions
Reasons for the Split-Off and the Reclassification, page 99
9.With a view to understanding how Liberty Media’s board determined to recommend the
split-off and “did not consider alternatives,” please elaborate upon why the “nature of the
particular assets and businesses to be held by SplitCo” lends itself to a split-off structure
as opposed to other alternatives, such as a spin-off and/or sale to a third-party purchaser.
10.We note your disclosure that “[t]he aggregate trading value of SplitCo's common stock
and Liberty Media's common stock is expected to exceed the aggregate trading value of
Liberty Media's existing common stock,” and that “Liberty Media believes that the public
markets continue to apply a meaningful discount to the Liberty SiriusXM common stock,
Liberty Braves common stock and Liberty Formula One common stock . . . .”  We also
note your disclosure that the split-off of the Liberty Braves business will reduce the
valuation discount currently applied to the Liberty Braves common stock.
Please elaborate upon the Liberty Media board’s use of the Liberty Braves Group tracking
stock share price as a pricing reference, specifically discussing the board's consideration
of the tracking stock discount reflected in Liberty Brave's share price, if any.
11.We note the investor presentation published on Liberty Media’s website as of November
21, 2022, which communicates to investors that there is “high demand for sports assets,”
and also cites various examples highlighting an “influx of alternative buyers” in the
market as well as certain “teams sold to traditional buyer base” and certain “rumored sale
processes.”  We also note, as reported by the Hollywood Reporter, Liberty Media’s CEO
Greg Maffei’s statement following such investor presentation that “[a]mong baseball
teams, Baltimore and Washington are rumored to be contemplating a sale. We’d argue, I
think with some reasons, that the Braves are a far more attractive asset.”  Please tell us
what consideration Liberty Media’s board gave to such market assessment as well as Mr.
Maffei’s statement in evaluating and recommending the split-off, and revise as
appropriate.
12.We note your discussion of how Liberty Media’s board considered the potentially
negative factors, including “potential tax liabilities that could arise from the Split-Off.”
Please expand your discussion to also address whether the board considered the specific
limitations, to be set forth in the tax sharing agreement, on SplitCo’s activities that will be
required to preserve the tax-free treatment of the split-off transaction.

 FirstName LastNameRenee L. Wilm
 Comapany NameAtlanta Braves Holdings, Inc.
 January 18, 2023 Page 5
 FirstName LastName
Renee L. Wilm
Atlanta Braves Holdings, Inc.
January 18, 2023
Page 5
Description of SplitCo's Business, page 128
13.We note your “exclusive operating rights to [Truist Park] via a 30-year Stadium Operating
Agreement with Cobb County and the Cobb-Marietta Coliseum and Exhibit Hall
Authority.”  To the extent that such operating agreement is material to your baseball
segment, please revise to summarize its material terms (including any termination rights),
include appropriate risk factor disclosure in the event of termination, and file the
agreement as an exhibit to the registration statement.  Please refer to Item
601(b)(10)(ii)(D) of Regulation S-K.
14.We note your investor presentation includes certain metrics related to the Atlanta Braves
business, including the number of tickets sold at Truist Park as well as the number of
visitors at Battery Atlanta.  To the extent such metrics are material to your business,
please revise to describe how you measure such metrics and assess the related results.
15.We note your disclosure that “Braves Holdings competes with the other MLB Clubs for a
limited pool of player, coaching and managerial talent” and that “[t]his talent contributes
to the Braves’ record and league standings, which are critical components of Braves
Holdings’ competitiveness.”  We also note your disclosure on page F-59 that certain
contractual obligations extend through 2032, as well as your investor presentation
disclosure that you have “secured young players under long-term contracts” such as
“Strider, Riley, Acuna, Harris, Olson [and] Albies.”  To the extent that you deem your
entry into long-term contracts with players as a material part of your business, please
revise to disclose as such and include a more robust a discussion of the market demand
and competitive conditions to secure such long-term contracts.  Please refer to Item
101(c)(1) of Regulation S-K.
16.We note your investor presentation discloses certain ESG results, including that the
Liberty Braves group “[c]ollected more than 200 tons of waste for recycling during the
2021 season.”  We also note Liberty Media’s discussion of its ESG approach and results
on its website, including its SASB disclosure for the year ended December 31, 2021.
Please advise us what consideration you gave to providing the same type of ESG-related
disclosure for the Atlanta Braves’ business here as you provided in your investor
presentation and on your website.
17.Please disclose by what basis "[t]he Battery Atlanta has one of the highest-capacity
networks serving any mixed-use development in the nation."

 FirstName LastNameRenee L. Wilm
 Comapany NameAtlanta Braves Holdings, Inc.
 January 18, 2023 Page 6
 FirstName LastName
Renee L. Wilm
Atlanta Braves Holdings, Inc.
January 18, 2023
Page 6
18.We note your disclosure that your total Adjusted OIBDA was $47,357,000 and your
Adjusted OIBDA attributed to your mixed-use development segment generated
$26,093,000 for the nine months ended September 30, 2022.  Given that your mixed-use
development segment generates a material portion of your Adjusted OIBDA, please
discuss the general terms of your rental income, parking and advertising sponsorship
agreements through which you primarily derive revenue, and to the extent that you
substantially depend on any particular agreements, please summarize their material terms
and file such agreements as exhibits to the registration statement.
19.We note your disclosure that failure by an MLB club to comply with the Debt Service
Rule during two consecutive fiscal years may lead to certain remedial measures, including
the prohibition on the incurrence of additional indebtedness and repayment of outstanding
indebtedness. To provide additional context for investors, please disclose whether the
Atlanta Braves have been in compliance with the Debt Service Rule during the last two
fiscal years.
Splitco Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 157
20.In connection with the split-off, you plan to enter agreements with Liberty Media to
include a services agreement, aircraft time sharing agreements, a facilities sharing
agreement, a tax sharing agreement and a registration rights agreement.  Please
disclose any material favorable or unfavorable impact these agreements may have on your
results of operations and/or liquidity.  Refer to Item 303(b) of Regulation S-K.
21.Please disclose any material favorable or unfavorable impact expiring and new player
contracts may have on your results of operations.  Refer to Item 303(b)(2) of Regulation
S-K.
22.We note your disclosure on page 43 that “[i]Income from postseason play (after reduction
for allocable postseason share payments) contributed approximately $67.8 million and
$7.8 million of