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                                                           March 13, 2019

James W. Barge
Chief Financial Officer
Lions Gate Entertainment Corp.
2700 Colorado Avenue
Santa Monica, California 90404

       Re: Lions Gate Entertainment Corp.
           Form 10-K for the Fiscal Year Ended March 31, 2018
           Form 8-K furnished February 7, 2019
           File No. 001-14880

Dear Mr. Barge:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended March 31, 2018

Management's Discussion and Analysis
Results of Operations, page 57

1.    We note your disclosure that for fiscal year 2018, pretax income is
composed of $972.8
      million of international income and $824.1 million of loss from the
United States. In light
      of the fact that Note 15 reflects the majority of revenue is derived in
the U.S. with a
      minimal amount in Canada, and 17% in other foreign countries, please tell
us, and
      consider expanding your disclosure in MD&A to discuss the nature of the
foreign
      operations generating this significant amount of income.
Financial Statements
Notes to Audited Consolidated Financial Statements
5. Investments, page F-22

2.    We note your disclosure on page F-22 that you recorded $47.8 million of
losses related to
 James W. Barge
Lions Gate Entertainment Corp.
March 13, 2019
Page 2
         "other" equity method investees. Please tell us how you assessed the
guidance in Rule 4-
         08(g) in disclosing summarized financial information of equity method
investees that meet
         the significance threshold in Rule 1-02(w). In this regard it should
be noted that the
         significance threshold for the footnote disclosure is 10%.
Form 8-K furnished February 7, 2019

Exhibit 99.1, page 1

3.       To avoid placing undue prominence on Adjusted OIBDA, a non-GAAP
measure, your
         header on the first page of your earnings release should include a
presentation of the most
         comparable GAAP measure in a location with equal or greater
prominence. Please review
         the guidance in our Compliance and Disclosure Interpretations updated
April 4, 2018,
         specifically question 102.10, when preparing your next earnings
release. Reference is
         made to Item 2.02, Instruction 2, of Form 8-K and the requirements of
paragraph (e)(1)(i)
         of Item 10 of Regulation S-K. Your presentation of Free Cash Flow
should be similarly
         revised.
4.       We note that your reconciliation of free cash flow includes
adjustments for the net change
         in production loans, shareholder litigation charges, and interest
paid. Since free cash flow
         is typically calculated as cash flow from operations adjusted by
capital expenditures and
         your definition of free cash flow differs from the typical definition
per Question 102.07 of
         the C&DIs on non-GAAP measures updated April 4, 2018, please revise
the title of this
         non-GAAP measure so it is not confused with free cash flow as
typically calculated.
       In closing, 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.

       You may contact Heather Clark at 202-551-3624 or Claire Erlanger at
202-551-3301 with
any questions.



FirstName LastNameJames W. Barge                               Sincerely,
Comapany NameLions Gate Entertainment Corp.
                                                               Division of
Corporation Finance
March 13, 2019 Page 2                                          Office of
Transportation and Leisure
FirstName LastName
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