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U.S. Securities and Exchange Commission

Securities Exchange Act of 1934
Rule 16b-7

November 3, 2011

Response of the Office of Chief Counsel
Division of Corporation Finance


Liberty Media Corporation
Liberty Interactive Corporation
Incoming letter dated October 14, 2011

Based on the facts presented, the Division’s view is as follows. Capitalized terms have the same meanings defined in your letter.

The described acquisitions and dispositions of securities pursuant to the Redemptions will be exempt from Section 16(b) of the Exchange Act pursuant to Rule 16b-7(a); provided, however, that such exemption would not be available to the extent of any non-exempt purchase and sale within less than six months, as specified in Rule 16b-7(d).

This position is based on the representations made to the Division in your letter. Different facts or conditions might require different conclusions.


Carolyn Sherman
Special Counsel

Incoming Letter:

The Incoming Letter is in Acrobat format.



Modified: 11/03/2011