September 24, 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 reviewed your August 14, 2024 response to our comment letter 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. Unless we
note otherwise, any references to prior comments are to comments in our July
23, 2024 letter.

Form 10-K for the Fiscal Year Ended December 31, 2023
Notes to Consolidated Financial Statements
Note 18. Segment Information, page 107

1.     We note your response to prior comment 6. Please explain management   s
reasons for
       structuring your organization into 9 operating segments.
2.     Please address the following as it relates to qualitative factors
considered in your
       determination to aggregate seven of your operating segments into the
Digital Media
       reportable segment:
           You state that your operating segments have a mix of advertising and
performance
           marketing revenue as well as subscription and license revenue.
Provide a breakdown
           of these two revenue streams for each operating segment for each
period presented
           and tell us how you considered the revenue composition in your
aggregation analysis.
           Please also quantify the amount of revenue recognized on a net basis
as compared to
           gross basis by operating segment and tell us how you considered such
differences in
           your analysis.
 September 24, 2024
Page 2

             Explain how, regardless of monetization method, you determined
that the nature of a
           subscription or licensing pricing model is similar to an
impression-based advertising
           pricing model. In your response, provide further details about the
type of
           subscriptions and licenses you offer and provide a breakdown of such
revenue by
           operating segment for each period presented.
             Describe for us the bundles that are sold to visitors to the
Gaming & Entertainment
           operating segment   s website and provide the amount of revenue
earned from these
           arrangements for each period presented.
             You indicate in your response that your customers include
individual consumers,
           businesses ranging from small to enterprise organizations, IT
vendors, online
           merchants, healthcare professionals and hospitals, and that there
may be elements of
           different customer classes in the operating segments. Please
describe these differences
           between the operating segments in further detail and explain how you
concluded the
           type or class of customers was similar for each of your operating
segments. In your
           response, provide us with a breakdown of revenue by customer type or
class for each
           operating segment, including the industries in which the customer
may operate as
           referenced in your response. To the extent revenue for any of the
operating segments
           are concentrated in a particular type or class of customers, tell us
the reason for such
           concentration and how that factored into your aggregation analysis.
             You state that the labor forces for each of the Digital Media
operating segments are a
           mix of full-time employees and freelancers who generate content in
order to drive
           traffic to websites and are often interchangeable among the
operating segments.
           However, you indicate that each of the operating segments have
editorial
           organizations that create content bespoke to the various verticals
in which you
           operate that can be in the form of data gathered from internet
traffic and sold. You
           also indicate you leverage original, curated, and licensed content
and data; research;
           editorial; and applications to drive traffic, and that the value
provided to the customer
           is in the form of specific content, information, or data curated for
each vertical, as
           well as data obtained by the website or app traffic. Please describe
in greater detail
           how the original and bespoke content and data used to drive traffic
to each of your
           websites, and the processes to produce it, is similar across your
operating segments,
           and how the labor forces are interchangeable. For example, describe
the employees
           and processes for developing content for healthcare professionals to
stay abreast of
           clinical, regulatory, and other developments in your Professional
segment, and the
           employees and processes for developing video game and entertainment
content for
           the Gaming & Entertainment segment, and explain in detail how they
are similar and
           different.
             We note the Connectivity operating segment includes Ookla (the
aggregation of data
           and related content for telecom, cable, and mobile carriers) and
Ekahau (software
           sales and services used to generate data used to assess the
performance of wi-fi signal
           strength data). Explain further how these services are similar to
other aggregated
           operating segments in which you earn revenue by generating traffic
to your websites,
           apps, or third-party platforms in order to monetize such traffic.
 September 24, 2024
Page 3
3.     Please address the following as it relates to qualitative factors
considered in your
       determination to aggregate two of your operating segments into the
Cybersecurity and
       Martech reportable segment:
           Describe in further detail the similarities and differences in the
nature of the services
           offered by each of Cybersecurity and Martech. In this regard,
Cybersecurity appears
           to offer endpoint and email security, security awareness training,
secure backup and
           file sharing, and virtual private network solutions, whereas Martech
appears to offer
           marketing, search engine optimization, and voice and text
communication services.
           Provide us with a breakdown of revenue by customer type or class
(e.g., SMBs,
           individuals and sole proprietorship) for each operating segment,
including the
           industries in which the customer may operate as referenced in your
response. To the
           extent revenue for any of the operating segments are concentrated in
a particular type
           or class of customers, tell us the percentage of such revenue, the
reason for such
           concentration, and how that factored into your aggregation analysis.
           Clarify the pricing mechanism used for each individual segment
(e.g., pricing based
           on user-count versus pricing based on usage levels). To the extent
subscriptions for an
           operating segment is more concentrated in one pricing mechanism,
tell us how that
           factored into your analysis.
4.     Please address the following as it relates to your assessment of similar
economic
       characteristics in your aggregation analyses:
           You disclose that segment performance is evaluated based on revenue
and profit or
           loss from operations. Please provide us with historical and
forecasted revenues and
           profit or loss from operations by year, as well as your analysis of
trends in revenue
           and in profit or loss from operations for each operating segment,
and your analysis of
           similarities and dissimilarities in such trends in your assessment
of economic
           similarity of the aggregated operating segments.
           We note you prepared your analysis using certain periods. Provide us
with this
           historical and forecasted information for the individual years
included in the periods
           you chose for your analysis for each operating segment and tell us
how you
           considered any trends, variances, or dissimilarities within each
period in your
           analysis.
           Tell us why your analysis only considers relative percentage
differences that exceed a
           certain percentage of average reportable segment margins in
assessing economic
           similarities. Also, tell us how you factored in the range of
differences in the actual
           margins between the aggregated operating segments in your analysis.
5.     Please also address the following as it relates to your assessment of
similar economic
       characteristics in aggregating seven of your operating segments into the
Digital Media
       reportable segment:
           You attribute certain discrete factors as impacting gross margin and
adjusted
           EBITDA margin of certain operating segments when compared with
Digital Media
           overall margins, such as content licensing costs in one brand within
your Gaming
           & Entertainment operating segment, products and services leveraging
the same data
           set and collection methodologies at your Connectivity operating
segment, and the
           volume in one brand within your Professional operating segment. Tell
us whether
           these factors, and any other factors impacting revenue, gross
margin, adjusted
 September 24, 2024
Page 4

           EBITDA, and profit or loss from operations between operating
segments, are unique
           to each of the impacted operating segments, and explain in detail
why they are not
           indicators of dissimilar economic characteristics. As part of your
response, tell us the
           amount of revenue and costs related to the brands referenced above
within the
           Gaming & Entertainment and Professional operating segments in
relation to the total
           operating segment for each period presented.
             Describe further how you considered forecasted information in your
analysis. To the
           extent you believe forecasted information results in further
alignment to Digital
           Media   s total margins, explain further how you reached such
conclusions. Also,
           clarify how you considered this information together with historical
data.

Form 10-Q for the Quarter Ended June 30, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations for the Three and Six Months Ended June 30, 2024
Digital Media and Cybersecurity and Martech Results, page 40

6.     We note the proposed revised disclosures provided in your response to
comment 3 where
       you included a quantitative discussion of the various factors, including
offsetting factors,
       that impacted segment revenue. However, in the June 30, 2024 Form 10-Q,
you attribute
       the decrease in advertising and performance marketing revenue to lower
revenue of $6.5
       million within the health and wellness and technology businesses,
partially offset by an
       increase in revenue in the gaming and entertainment business without
quantifying the
       decrease attributable to each of the health and wellness and technoloy
businesses or the
       offsetting increase in the gaming and entertainment business. Please
ensure that you will
       provide such quantification, when applicable, in your future filings.
       Please contact Megan Masterson at 202-551-3407 or Kathleen Collins at
202-551-3499 if
you have questions regarding comments on the financial statements and related
matters.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Technology
cc:   Jeremy Rossen