| STARZ, LLC | 8900 Liberty Circle |
| Englewood, CO 80112 | |
(T) 720-852-7700 | STARZ.COM |
December 20, 2012
VIA EDGAR
Mr. Larry Spirgel, Assistant Director
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street N.E.
Washington, D.C. 20549-3561
RE: Supplemental Letter for Acceleration Request
Starz, LLC, Starz Finance Corp. and Starz Entertainment, LLC
Registration Statement on Form S-4 (File No. 333-184551)
Dear Mr. Spirgel:
Transmitted herewith is a request for acceleration of the effective date of the Registration Statement on Form S-4 (Registration No. 333-184551) (the “Registration Statement”). In connection with the acceleration request, Starz, LLC and Starz Finance Corp. (the “Issuers”) and Starz Entertainment, LLC as a guarantor co-registrant (collectively with the Issuers, the “Company”) hereby acknowledge as follows:
1. Should the Securities and Exchange Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, such action does not foreclose the Commission from taking any action with respect to the Registration Statement.
2. The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement.
3. The Company may not assert such action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please contact the undersigned at (720) 852-7700 or our outside counsel, Jeffrey R. Kesselman at (303) 297-2900, with any questions.