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 May 20, 2025

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

 Re: GCI Liberty, Inc.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed May 6, 2025
 File No. 333-286272
Dear Ronald A. Duncan:

 We have reviewed your amended 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. Unless
we note
otherwise, any references to prior comments are to comments in our April 29,
2025 letter.

Amendment No. 1 to Registration Statement on Form S-1
Accounting Treatment, page 56

1. Your response to prior comment 6 states that the separation and
distribution
 agreement, the tax sharing agreement and the tax receivables agreement
are not
 expected to materially change the future results of GCI Liberty.
However, your
 response to prior comment 8 states that services agreement, facilities
sharing
 agreement, and an aircraft time sharing agreement, as described in the
registration
 statement on pages 122-124, as well as other public company costs, are
currently
 estimated to be less than $10 million per annum. In addition we note
your disclosure
 that "if the cash taxes payable by Liberty Broadband from the separation
exceed
 $420 million, GCI Liberty must pay to Liberty Broadband the value of the
portion of
 U.S. federal, state and local income tax benefits realized by GCI
Liberty as a result of
 May 20, 2025
Page 2

 certain tax elections made with respect to the separation that correspond
to taxes from
 the separation in excess of $420 million." In light of these factors,
please confirm that
 pro forma financial information are not necessary to reflect GCI Liberty
as
 an autonomous entity. Refer to Rule 11-01(a)(7) of Regulation S-X.
Index to Financial Statements
Combined Statements of Operations, page F-4

2. Your response to prior comment 9 states that operating expenses include
business
 direct costs, consumer direct costs, technology expense, other expenses,
and stock-
 based compensation expense. Please tell us how this presents your
operating expenses
 by function. Tell us whether operating expenses includes direct and
indirect selling
 expenses (e.g. advertising and selling costs paid to third parties and
compensation
 costs for sales employees) or general and administrative expenses (e.g.
direct costs of
 administering the business and other indirect costs excluding those
included in cost of
 sales). Tell us whether operating expenses include direct and indirect
costs related to
 the revenue caption. In this regard, explain how your presentation
complies with Rule
 5-03(b)(4) of Regulation S-X which requires the separate presentation of
selling,
 general and administrative expenses.
Notes to Combined Financial Statements
(1) Basis of Presentation, page F-7

3. Please clarify your response to prior comment 8 to explain whether the
corporate
 function for the operation of a public company is reflected in the
historical financial
 statements of GCI Liberty. If you have allocated common expenses, you
should
 disclose the allocation method used in the notes to the financial
statements along with
 management s assertion that the method used is reasonable. Refer to SAB
Topic
 1.B.1.
 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 Kathleen Krebs at 202-551-3350 or Larry Spirgel at
202-551-3815
with any other questions.

 Sincerely,

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