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    O’Melveny & Myers LLP
    T: +1 415 984 8700

    Two Embarcadero Center
    F: +1 415 984 8701

    28ᵗʰ Floor
    omm.com

    San Francisco, CA 94111-3823

    February 13, 2023
    C. Brophy Christensen

    D: +1 415 984 8793

    bchristensen@omm.com

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

Washington, D.C. 20549

 Re: Atlanta Braves Holdings, Inc.

Registration Statement on Form S-4

Filed December 21, 2022

File No. 333-268922

To the Staff of the Division of Corporation Finance:

On behalf of our client, Atlanta Braves Holdings, Inc.
(“SplitCo”), this letter sets forth SplitCo’s responses to the comments of the Staff of the Division of Corporation
Finance (the “Staff”) of the U.S. Securities and Exchange Commission set forth in its letter, dated January 18,
2023 with respect to the filing referenced above (the “Comment Letter”).

This letter and Amendment No.1 (“Amendment
No. 1”) to the Registration Statement on Form S-4 (File No. 333-268922) are being filed electronically via the
EDGAR system today.

For the Staff’s convenience, the text of
each comment from the Comment Letter is set forth below in bold, followed by SplitCo’s response. Capitalized terms used and not
defined herein have the meanings given in Amendment No. 1. Page and caption references in SplitCo’s responses correspond
to pages and captions in Amendment No. 1.

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 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.

Austin • Century City • Dallas •
Houston • Los Angeles • Newport Beach • New York • San Francisco • Silicon Valley • Washington, DC

Beijing
 • Brussels • Hong Kong • London • Seoul • Shanghai • Singapore • Tokyo

 ●  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.

Response: In response to the Staff’s
comment, SplitCo revised the disclosure on pages 17, 22, 50 and 105 of Amendment No. 1.

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.

Response: In response to the Staff’s
comment, SplitCo revised the disclosure on pages 15-16, 36, 59 and 63 of Amendment No. 1.

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.

Response: In response to the Staff’s
comment, SplitCo added the summary beginning on page 37 of Amendment No. 1.

Risk Factors

“The risk of injuries to key or popular players creates
uncertainty and could negatively impact financial results.”, page 44

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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.

Response: In response to the Staff’s
comment, SplitCo incorporated a new risk factor on pages 51-52 of Amendment No. 1.

“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.

Response: SplitCo respectfully
advises the Staff that SplitCo is not substantially dependent on the SSN agreement. SplitCo owns all of the Braves media content,
subject to MLB provisions, and only licenses the distribution of such content to the applicable service provider(s) under such
agreements. Further, based on recent transactions involving sports media rights across a variety of sports and the popularity of,
and demand for Braves’ content, SplitCo believes that if SplitCo’s existing agreement with SSN expired, was terminated
or otherwise needed to be replaced, including due to any bankruptcy of Diamond Sports Group, the parent company of SSN, SplitCo
would be able to enter into one or more licensing agreements with comparable service providers. SplitCo originally entered into the
agreement with SSN prior to the 2013 baseball season, selecting SSN over other alternative service providers, and in the process,
chose to consolidate its local media rights to a single service provider. Since entering into the agreement with SSN, the interest
in sports media rights remains very strong, in particular due to the emergence and success of various streaming services creating
new competition and distribution platforms, and the continued value of live sports as “appointment” viewing. In
addition, with the Braves’ recent on-field success of five (5) straight NL East division titles and the 2021 World
Series championship, SplitCo believes its Braves’ content is amongst the most sought-after content in professional
sports. As a result of the increased distribution platforms and competitors noted above, SplitCo believes there are more service
providers able to provide comparable distribution services for Braves’ content than there were at the time it entered into the
SSN agreement. Based
on the reasons above, SplitCo respectfully submits that the SSN agreement is not a material contract within the meaning of Item 601(b)(10)(ii)(B) of Regulation S-K.

    3

With respect to sponsorship relationships, SplitCo
respectfully advises the Staff that no individual sponsorship relationship contributes a material amount of revenue. Further, SplitCo
respectfully advises the Staff that sponsorship relationships are contracts of the type that are entered into in the ordinary course of
business, relationships that change regularly and are typically structured as short-term relationships. SplitCo is continually developing
new opportunities for new potential sponsors and believes it could easily obtain new or alternative sponsorship relationships. As such,
SplitCo has determined that it is not substantially dependent upon any of its advertising sponsorship relationships.

“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.

Response: In response to the Staff’s
comment, SplitCo revised the disclosure on pages 58 and 171 of Amendment No. 1.

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.

    4

Response: In response to the Staff’s
comment, SplitCo revised the disclosure on pages 62 and 211-212 of Amendment No. 1 and made conforming changes to the exclusive
forum provision in the SplitCo restated charter.

“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, 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.

Response: In response to the Staff’s comment regarding clarification that Liberty Media is considered an exempt person, SplitCo revised the
disclosure on pages 24, 60, 62, 119 and 210 of Amendment No. 1. SplitCo respectfully advises the Staff that as disclosed on
pages 24 and 119 of Amendment No. 1, SplitCo expects that the SplitCo restated charter will include similar ownership limitation
provisions as are included in the existing Liberty Media certificate of incorporation. It is expected that the SplitCo restated charter
will contain the only ownership limitation provision generally applicable to SplitCo’s equity. Liberty Media does not intend to
enter into any agreement with MLB governing ownership limitation terms with respect to SplitCo.

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.

Response: In response to the Staff’s
comment, SplitCo revised the disclosure on pages 114-115 of Amendment No. 1. SplitCo respectfully advises the Staff that Liberty
Media’s board and management determined that the Split-Off transaction would be the best structure because a spin-off transaction
would not involve the full redemption of the Liberty Braves common stock, and therefore would not achieve the same simplification of the
capital structure of Liberty Media in connection with the separation of SplitCo’s business as the Split-Off, and a third party sale
would result in adverse tax consequences to Liberty Media.

    5

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.

Response: In response to the Staff’s
comment, SplitCo revised the disclosure on pages 20-21, 111 and 112 of Amendment No.1.

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.

Response: As described on page 20-21, 112 and 114-115 of Amendment No.1, Liberty Media’s board of directors took into account