September 28, 2018

Peter Halt
Chief Financial Officer
TiVo Corporation
2160 Gold Street
San Jose, CA 95002

       Re: TiVo Corporation
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed February 27, 2018
           Form 10-Q for the Quarterly Period Ended March 31, 2018
           Filed May 10, 2018
           File No. 001-37870

Dear Mr. Halt:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-Q for the Quarterly Period Ended March 31, 2018

Note 1. Basis of Presentation and Summary of Significant Accounting Policies
Revenue Recognition
Arrangements with Multiple System Operators for the TiVo Service, page 10

1.    Please help us better understand the underlying nature of the TiVo
Service and tell us if
      you determined that the service was a functional license to intellectual
property. In
      arrangements where you host the service, tell us how you considered
whether you have
      provided software subject to a hosting arrangement. Also, tell us your
basis for
      recognizing revenue related to fixed fees ratably over the license
period. Lastly, tell us if
      you are applying the guidance for sales-based or usage-based royalties in
these
 Peter Halt
TiVo Corporation
September 28, 2018
Page 2
         arrangements. Refer to ASC 606-10-55-54(a) and ASC 606-10-55-65.
Note 5. Revenues
Contract Balances, page 16

2.       We note your statement regarding the amount of revenue that is
expected to be recognized
         from remaining performance obligations over the remainder of 2018.
Please tell us, and
         revise to clarify, when you expect to recognize the remaining balance.
Refer to ASC 606-
         10-50-13.
       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
absence of action by the staff.

       You may contact Rebekah Lindsey, Staff Accountant at (202) 551-3303 or
Christine
Dietz, Assistant Chief Accountant at (202) 551-3408 with any questions.



                                                            Sincerely,
FirstName LastNamePeter Halt
                                                            Division of
Corporation Finance
Comapany NameTiVo Corporation
                                                            Office of
Information Technologies
September 28, 2018 Page 2                                   and Services
FirstName LastName