October 16, 2024

Charles H. R. Bracken
Chief Financial Officer
Liberty Global Ltd.
Clarendon House, 2 Church Street
Hamilton HM 11, Bermuda

       Re: Liberty Global Ltd.
           Form 10-K for the Year Ended December 31, 2023
           Filed February 15, 2024
           Response Dated September 6, 2024
           File No. 001-35961
Dear Charles H. R. Bracken:

        We have reviewed your September 6, 2024 response to our comment letter
and have
the following comment(s).

       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 August
30, 2024 letter.

Form 10-K for the Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Discussion and Analysis of our Reportable Segments, page II-6

1.     Please revise the MD&A discussions of your reportable segment results so
they
       are consistent with your footnote segment disclosures revised in
accordance with ASC
       280.
Note 19. Segment Reporting, page II-116

2.     We note your response to prior comment 1. We also note the proposed
disclosures
       present revenues that combines revenues from external customers and
intersegment
       revenues prior to eliminating intersegment revenue. We continue to
believe you
       should separately disclose revenues from external customers and revenues
from
 October 16, 2024
Page 2

       transactions with other operating segments, as required by ASC
280-10-50-22(a) and
       (b). Please revise or explain the basis for your presentation.
3.     We note your proposed disclosure to prior comment 2. Please explain to
us what you
       mean by "significant accounting policies of our reportable segments are
principally
       the same" as those of Liberty Global. Tell us what "principally the
same" means.
       Also, tell us how the accounting policies differ.
4.     We note your response to prior comment 3. We continue to believe your
proposed
       disclosure does not comply with ASC 280-10-50-30(b) that requires the
total of the
       reportable segments    measures of profit or loss be reconciled to the
public entity   s
       consolidated income before income taxes and discontinued operations.
Please revise
       your reconciliations to start with the total of the measures of profit
or loss for all of
       your reportable segments. Please similarly revise other required
reconciliations, such
       as reportable segments    revenues and assets, to start with the total
of the reportable
       segments    amounts. See ASC 280-10-50-30(a), (c), and (d). If you do
not agree,
       please explain the basis for your presentation.
        Please contact Joseph Cascarano at 202-551-3376 or Robert Littlepage at
202-551-
3361 if you have questions regarding comments on the financial statements and
related
matters.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Technology