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 April 29, 2025

Ronald A. Duncan
President and Chief Executive Officer
GCI Liberty, Inc.
12300 Liberty Blvd.
Englewood, Colorado 80112

 Re: GCI Liberty, Inc.
 Registration Statement on Form S-1
 Filed March 31, 2025
 File No. 333-286272
Dear Ronald A. Duncan:

 We have reviewed your registration statement and have the following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.

Registration Statement on Form S-1
Cover Page

1. Please revise your cover page to describe the disparate voting rights
between the
 different series of your common stock that are being distributed to
Liberty Broadband
 common stockholders.
Question and Answers
Q: Is GCI Group common stock a tracking stock?, page 11

2. We note that the GCI Group common stock being distributed to Liberty
Broadband
 shareholders has features consistent with tracking stock and that the
GCI Group stock
 may become a tracking stock without the approval of GCI Liberty s
stockholders after
 the separation. We also note that GCI Liberty s articles are being
amended prior to the
 separation so that Ventures Group common stock, which also has features
consistent
 with tracking stock, is already authorized and can be issued without
shareholder
 April 29, 2025
Page 2

 approval after the separation. Please discuss why you have structured
the separation in
 this manner and are not, for example, distributing to Liberty Broadband
shareholders
 shares of both the GCI Group and GGI Ventures Group common stock.
Discuss how
 the implementation of two groups of tracking stock and any issuance of
the GCI
 Ventures Group shares after the separation create additional risks,
including the
 dilution of Liberty Broadband shareholders ownership in GCI Liberty
after the
 separation and a potential impact on the market value of their GCI Group
shares.
 Highlight this information on the cover page with cross-references to
the specific risk
 factors related to tracking stocks.
Risk Factors
GCI depends on a limited number of third-party vendors to supply communications
equipment, page 36

3. We note your disclosure regarding the risk associated with your reliance
on a limited
 number of third-party vendors. Please revise your disclosure here and
elsewhere as
 appropriate to discuss whether you enter into written agreements with
these third-
 party vendors. If so, please describe the material terms of these
agreements and file
 any material written agreements if required by Item 601(b)(10) of
Regulation S-K.
The Separation
Reasons for the Separation, page 48

4. Please discuss why the Liberty Broadband board structured the separation
as it has
 been structured and the factors considered by the board. For example,
specifically
 address the board s reasons for drafting the GCI Liberty articles so
that the two
 authorized classes of GCI Liberty common stock have features consistent
with
 tracking stock and the implementation of a tracking stock structure can
occur without
 shareholder approval. Also address the board s consideration of the
benefits and
 detriments to Liberty Broadband (or Charter Communications, as
applicable), Liberty
 Broadband shareholders who will receive the distribution of GCI shares,
and GCI
 Liberty of the tax consequences of the separation and of the tax
receivables
 agreement.
Accounting Treatment, page 54

5. Please tell us how you considered whether the separation from Liberty
Broadband
 would qualify as a reverse spin-off. Please include the basis for your
conclusion.
6. Please tell us what consideration you gave to providing pro forma
information for the
 separation from Liberty Broadband. In this regard, we note that you will
enter into the
 separation and distribution agreement, the tax sharing agreement and the
tax
 receivables agreement due to the separation.
Certain Relationships and Related Party Transactions
Related Party Agreements Relating to GCI Liberty
Malone Nonvoting Side Letter, page 119

7. Please file the Malone Nonvoting Side Letter as an exhibit to the
registration
 statement or advise why it is not required to be filed. Refer to Item
601(b)(10)(ii)(A)
 of Regulation S-K.
 April 29, 2025
Page 3

Index to Financial Statements
Combined Statements of Operations, page F-4

8. Please disclose how you identified and allocated expenses incurred on
your behalf or
 explain why there are no expenses identified and allocated for the years
ended
 December 31, 2024 and 2023. Refer to SAB Topic 1.B.1.
9. Tell us how you considered Rule 5-03 of Regulation S-X for presenting
revenue and
 expense line items on the face of the combined statements of operations.
Please revise
 or advise.
Notes to Combined Financial Statements
Revenue Recognition, page F-11

10. You disclose that you account for the upgrade option under the Upgrade
Now
 Program as a right of return with a reduction of Revenue and Operating
expense for
 handsets expected to be upgraded based on historical data. Please tell
us how you
 determined that this right should be accounted for as a right of return.
Tell us how you
 considered whether this upgrade right represents a guarantee liability
or a lease. Refer
 to ASC 460 and ASC 606-10-55-66 to 78. Please cite the accounting
literature that
 supports your accounting.
11. Please tell us how you considered disclosing revenue recognized at a
point in time
 versus over time. Refer to ASC 606-10-55-91(f).
12. Please tell us and disclose if any of your contracts are month-to-month
and are
 cancellable at any time without penalty. In addition, please tell us and
disclose, if
 material, whether a significant financing component exists in any of
your fixed-term
 plans and device payment plans (i.e., payment plans greater than one
year). Refer to
 ASC 606-10-32-15 to 606-10-32-20.
13. You recognize revenue for product sales when a customer takes possession
of the
 equipment in Data arrangements. Please clarify whether your customers
take
 possession of the product before it is delivered. Refer to ASC
606-10-55-81 to 55-88.
 Please advise or revise your disclosures.
Contract Balances, page F-13

14. You disclose that you had deferred revenue of $33 million and $43
million at
 December 31, 2024 and 2023, respectively. Please reconcile these amounts
to your
 combined balance sheets. Please ensure that your disclosure of contract
assets and
 liabilities complies with ASC 606-10-50-8.
 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.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 April 29, 2025
Page 4

 Please contact Amanda Kim at 202-551-3241 or Stephen Krikorian at
202-551-3488
if you have questions regarding comments on the financial statements and
related
matters. Please contact Matthew Crispino at 202-551-3456 or Kathleen Krebs at
202-551-
3350 with any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Technology
cc: Jeeho Lee, Esq.
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