William Bardeen

Executive Vice President and

Chief Financial Officer

T 212 556 7001

bardewt@nytimes.com

620 8th Avenue

New York, NY 10018

December 8, 2023

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Re:    The New York Times Company

Form 10-K for the Year Ended December 31, 2022

Filed February 28, 2023

File No. 001-05837

Ladies and Gentlemen:

The following sets out the response of The New York Times Company (the “Company”, “we”, “us” or “our”) to the comment set forth in your letter dated November 27, 2023, regarding the Company’s Annual Report on Form 10-K for the year ended December 31, 2022 (the “2022 10-K”). For ease of review, we have set out the comment together with the Company’s response.

16. Segment Information, page 111

1.We note your response to comment 5 and the expanded non-GAAP reconciliation for consolidated adjusted operating costs that you intend to include in future filings. Please further revise your proposed disclosures to also reconcile adjusted operating costs by individual segment to the corresponding GAAP measure. The reconciliation should include detail of all significant adjusting amounts.

Securities and Exchange Commission

December 8, 2023

Page 2

Response:

We acknowledge the Staff’s comment and will update future interim and annual filings to also reconcile adjusted operating costs by individual segment to the corresponding GAAP measure. This expanded reconciliation will be substantially as follows:

	Years Ended
	December 31, 2022						December 26, 2021
	(52 weeks and six days)(1)						(52 weeks)
(in thousands)	NYTG		The Athletic		Consolidated		NYTG		The Athletic		Consolidated
Total operating costs	$	1,955,169	$	151,185	$	2,106,354	$	1,806,843	$	—	$	1,806,843
Less:
Depreciation and amortization	57,392		25,262		82,654		57,502		—		57,502
Severance	4,509		160		4,669		882		—		882
Multiemployer pension plan withdrawal costs	4,871		—		4,871		5,150		—		5,150
Acquisition-related costs	34,712		—		34,712		—		—		—
Multiemployer pension plan liability adjustment	14,989		—		14,989		—		—		—
Impairment charge	4,069		—		4,069		—		—		—
Lease termination charge	—		—		—		3,831		—		3,831
Total adjusted operating costs	$	1,834,627	$	125,763	$	1,960,390	$	1,739,478	$	—	$	1,739,478
(1) The results of The Athletic have been included in our Consolidated Financial Statements beginning February 1, 2022.

____________________

If there are any questions, please contact the undersigned at 212-556-7001, or Diane Brayton, Executive Vice President and General Counsel, at 212-556-5995.

Very truly yours,

/s/ William Bardeen

William Bardeen

Executive Vice President and

Chief Financial Officer

(Principal Financial Officer)

cc:

Diane Brayton, The New York Times Company

Andrew Blume, SEC Staff

Claire Erlanger, SEC Staff

Morgan, Lewis & Bockius LLP

Ernst & Young, LLP