July 23, 2024

Bret Richter
Chief Financial Officer
Ziff Davis, Inc.
114 5th Avenue
New York, NY 10011

        Re: Ziff Davis, Inc.
            Form 10-K for the Fiscal Year Ended December 31, 2023
            File No. 000-25965
Dear Bret Richter:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for the Fiscal Year Ended December 31, 2023
Item 7. Management   s Discussion and Analysis of Financial Condition and
Results of Operations
Performance Metrics, page 43

1.     We note your performance metrics for subscriptions and licensing are
presented on a
       consolidated basis. Please provide us with a breakdown of subscription
and
       licensing metrics separately for each segment. Explain why this
information is provided
       on a consolidated basis considering the segment structure used by
management for
       making operating and investment decisions and assessing performance, or
revise to
       disclose separate metrics for each of your segments. In addition, tell
us how perpetual
       licenses factor into your calculations and in your response, provide us
with the amount of
       up-front license revenue included in your calculations for each period
presented. Refer to
       Item 303(b) of Regulation S-K.
 July 23, 2024
Page 2
Critical Accounting Policies and Estimates
Goodwill and Indefinite-Lived Intangible Assets, page 45

2.     We note from your disclosure on page 87 that you reassessed the fair
value of certain
       reporting units within your Digital Media reportable segment due to a
forecasted
       reduction in revenue and profitability and an increase in interest rates
and market
       volatility. We further note that you impaired one of the reporting units
in each of fiscal
       2023 and 2022. Please revise to clarify whether any of the other
reporting units are at risk
       of impairment and if so, disclose the percentage by which fair value
exceeded carrying
       value as of the most recent test. Also, include a description of
potential events and/or
       changes in circumstances that could reasonably be expected to negatively
affect the key
       assumptions used in your evaluation. Otherwise, state, if true, that the
fair value of each of
       your reporting units are substantially in excess of carrying value and
are not at risk of
       failing. Refer to Item 303(b)(3) of Regulation S-K.
Results of Operations for the Years Ended December 31, 2023 and 2022
Digital Media and Cybersecurity and Martech Results, page 52

3.     You indicate that revenues in your Digital Media segment were effected
by an organic
       decline in certain businesses, offset in part by incremental revenue
from businesses
       acquired and organic growth in other businesses. You also indicate that
the decline in
       Cybersecurity and Martech net sales was due to an organic decline in
certain businesses.
       Please revise to quantify each material factor, including any offsetting
factors, that
       impacted your segment revenue. To the extent revenue was impacted by
specific
       businesses, revise to indicate as such and the reasons for such change.
For example, we
       note references in the fourth quarter earnings call transcripts to items
such as the health
       business being a steady contributor of growth with Lose It achieving
record bookings
       while Offers.com faced continued pressure and the shopping business
tipped into negative
       territory. As another example, you state VPN represented the vast
majority of the drag in
       the Cybersecurity and Martech segment.
Consolidated Financial Statements
Consolidated Statements of Operations, page 61

4.     Please tell us whether direct costs is intended to represent cost of
revenue. If so, revise to
       clarify as such and address whether depreciation and amortization is
included in such
       costs. Refer to SAB Topic 11.B. To the extent direct costs do not
represent cost of
       revenue, revise to separately present cost of revenue on the face of
your consolidated
       statement of operations. Refer to Rule 5-03(b)(2) of Regulation S-X.
Notes to Consolidated Financial Statements
Note 12. Commitments and Contingencies, page 96

5.     To the extent it is reasonably possible you will incur losses in excess
of amounts recorded
       related to both your litigation and non-income related tax matters,
please revise to disclose
       an estimate of the reasonably possible losses or range of loss or state
that such an estimate
       cannot be made. Refer to ASC 450-20-50-3 through 50-4.
 July 23, 2024
Page 3
Note 18. Segment Information , page 107

6.     You state that the company aggregates its operating segments into two
reportable
       segments: Digital Media and Cybersecurity and Martech. Please identify
for us each of
       the operating segments included in each of your reportable segments.
Explain to us, in
       sufficient detail, how you determined your operating segments meets the
aggregation
       criteria with a detailed analysis of each of the criteria described in
ASC 280-10-50-11,
       including how you determined such operating segments have similar
economic
       characteristics.

       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.

       Please contact Megan Akst at 202-551-3407 or Kathleen Collins at
202-551-3499 with
any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Technology
cc:   Jeremy Rossen