United States securities and exchange commission logo





                           December 14, 2023

       Brian Capo
       Chief Accounting Officer
       Live Nation Entertainment, Inc.
       9348 Civic Center Drive
       Beverly Hills, CA 90210

                                                        Re: Live Nation
Entertainment, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            Form 10-Q for the
Quarterly Period Ended September 30, 2023
                                                            File No. 001-32601

       Dear Brian Capo:

              We have limited our review of your filings 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, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Executive Overview, page 30

   1.                                                   We note consolidated
AOI is a non-GAAP measure. Refer to Question 104.04 of the
                                                        Compliance and
Disclosure Interpretations on Non-GAAP Financial Measures. Please
                                                        provide disclosure
pursuant to Item 10(e)(1)(i) of Regulation S-K. This comment also
                                                        applies to your Form
10-Q for the Quarterly Period Ended September 30, 2023 and
                                                        Exhibit 99.1 to Form
8-K filed November 2, 2023.
 Brian Capo
FirstName
Live NationLastNameBrian
            Entertainment, Capo
                           Inc.
Comapany14,
December   NameLive
              2023 Nation Entertainment, Inc.
December
Page 2    14, 2023 Page 2
FirstName LastName
Consolidated Results of Operations, page 32

2.       You present consolidated results of operations in constant currency
for the years ended
         December 31, 2022, and 2021. It appears that you are presenting a
partial income
         statement of non-GAAP measures. Please tell us your consideration of
Question 102.10(c)
         of the Compliance and Disclosure Interpretations on Non-GAAP Financial
Measures and
         Item 10(e)(1)(i)(A) of Regulation S-K. This comment also applies to
your Form 10-Q for
         the Quarterly Period Ended September 30, 2023.
Form 10-Q for the Quarterly Period Ended September 30, 2023

Notes to Consolidated Financial Statements
Note 6 - Commitments and Contingent Liabilities, page 17

3.       Please tell us what consideration you gave to disclosing more detailed
information on the
         Astroworld litigation pursuant to ASC 450-20-50- 3 through 5 including
disclosure of the
         damages sought. In addition, you state you do not currently possess
sufficient information
         to determine a range of reasonably possible liability. Please explain
to us what factors are
         causing your inability to estimate and when you expect those factors
to be alleviated.
         Explain to us the procedures you undertake to attempt to develop a
range of reasonably
         possible loss for disclosure.
       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 Nasreen Mohammed at 202-551-3773 or Adam Phippen at
202-551-3336
with any questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Trade
& Services