December 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 October 18, 2024
           File No. 001-35961
Dear Charles H. R. Bracken:

        We have reviewed your October 18, 2024, response to our comment letter
and have
the following comment.

       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
the 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 October
16, 2024, letter.

Form 10-K for the Fiscal Year Ended December 31, 2023
Note 19. Segment Reporting, page II-116

1.     We note your response to prior comment 4. We also note that "Total
Reportable
       Segment" Adjusted EBITDA represents a required ASC 280 measure; however,
       please note that the measure on a total consolidated basis represents a
non-
       GAAP measure and that Item 10(e)(1)(ii)(C) of Regulation S-K prohibits
the
       presentation of non-GAAP measures in the financial statement footnotes.
If you plan
       to present such measure outside of your consolidated financial
statements, please label
       it as a non-GAAP financial measure and ensure that your presentation and
disclosures
       fully comply with non-GAAP rules, including Item 10(e) of Regulation S-K
and
       the Non-GAAP C&DI's.
 December 16, 2024
Page 2

        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