December 4, 2024

Naveen Chopra
Chief Financial Officer
Paramount Global
1515 Broadway
New York, New York 10036

       Re: Paramount Global
           Form 10-K for the Fiscal Year Ended December 31, 2023
           Form 10-Q for the Nine Months Ended September 30, 2024
           File No. 001-09553
Dear Naveen Chopra:

       We have reviewed your filings 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-Q for the Nine Months Ended September 30, 2024
Notes to Consolidated Financial Statements
2) Programming and Other Inventory, page 13

1.     With regard to programming charges that occurred in 2023 and during
2024:
           Tell us in detail why you believe these charges are different from
your regular
          review of content.
           Tell us where normal program impairments are recorded in your
consolidated
          statement of operations, including their values.
           Tell us if and how the impaired content was evaluated in prior
periods.
 December 4, 2024
Page 2

3) Impairment, Restructuring and Transaction-Related Costs, page 14

2.     We note you disclosed in your 10-K that "it is more likely than not that
the fair value
       of each of our reporting units continues to substantially exceed their
respective
       carrying amounts." Please tell us what factors changed between this
assessment and
       the second quarter assessment that led to a significant impairment in
Cable reporting
       unit. Provide a timeline of various indicators of impairment and why
these indicators
       were not apparent in 2023 and earlier in 2024.
3.     We note in the second quarter of 2024, you assessed relevant factors
that could impact
       the fair value of your reporting units including the estimated total
company market
       value indicated by the Transactions and the NAI Transaction. In light of
the
       elimination of the entire historic balance of goodwill in your
preliminary purchase
       price allocation, please explain to us why you did not record a full
impairment of
       goodwill in your financial statements.
5) Revenues, page 18

4.     We note your statement that, "the three and nine months ended September
30, 2024
       include advertising revenue for amounts recognized during 2024 for the
       underreporting of revenue by an international sales partner in prior
periods."
       Provide detailed information about the underreporting of revenue and
their values, for
       all affected periods.
12) Segment Information, page 27

5.     Based on disclosure on page 60, it appears that within your TV Media
segment you
       have two reporting units, Cable Networks and one other reporting unit.
Tell us if these
       two reporting units are also operating segments. If they are operating
segments tell us
       why you believe aggregating them into one reportable segment is
appropriate. Refer
       to guidance in ASC 280-10-50-11.
Management   s Discussion and Analysis of Results of Operations and Financial
Condition
Reconciliation of Non-GAAP Measures, page 36

6.     We note your non-GAAP measures exclude the costs related to "programming
       charges." Please explain to us in greater detail the nature of these
charges and whether
       they relate to your revenue generating activities. As part of your
response, tell us how
       you considered the guidance outlined in Question 100.01 of the Division
of
       Corporation Finance Compliance & Disclosure Interpretations on Non-GAAP
       Financial Measures in determining the adjustments are appropriate.
Direct-to-Consumer, page 51

7.     To help investors understand your subscriber metric, please break out
the portion of
       customers registered in a free trial.
        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.
 December 4, 2024
Page 3

        Please contact Inessa Kessman at 202-551-3371 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