August 23, 2018 Chandler Bigelow Executive Vice President and Chief Financial Officer Tribune Media Company 515 North State Street Chicago, IL 60654 Re: Tribune Media Company Form 10-K for the Fiscal Year Ended December 31, 2017 Filed March 1, 2018 Form 10-Q for the Quarterly Period Ended June 30, 2018 Filed August 9, 2018 File No. 001-08572 Dear Mr. Bigelow: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-Q For the Quarterly Period Ended June 30, 2018 Financial Statements Note 1: Basis of Presentation and Significant Accounting Policies Revenue Recognition, page 13 1. We note certain advertising contracts have guarantees of audience member views. Please clarify if these guarantees are treated as variable consideration in determining your transaction price. Refer to ASC 606-10-32-5 and 606-10-50-20. In closing, 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 Chandler Bigelow Tribune Media Company August 23, 2018 Page 2 absence of action by the staff. You may contact Claire DeLabar, Staff Accountant at (202) 551-3349 or Terry French, Accountant Branch Chief at (202) 551-3828 with any questions. FirstName LastNameChandler Bigelow Sincerely, Comapany NameTribune Media Company Division of Corporation Finance August 23, 2018 Page 2 Office of Telecommunications FirstName LastName