October 17, 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 Form 10-Q for the Quarterly Period Ended June 30, 2018 Response Dated September 7, 2018 File No. 001-08572 Dear Mr. Bigelow: We have reviewed your September 7, 2018 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our August 23, 2018 letter. 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 your response to our comment letter dated August 23, 2018. Please revise your future filings to clarify that you recognize revenue on your advertising contracts with guarantees based on the proportion of audience member views delivered in relation to the total guaranteed audience member views in the contract. Please also revise to explain, as you do in your response, how you address scenarios where the guaranteed number of Chandler Bigelow Tribune Media Company October 17, 2018 Page 2 audience views is not achieved through the initial package of advertisements. Please refer to ASC 606-10-50-12. You may contact Claire DeLabar, Staff Accountant at (202) 551-3349 or Terry French, Accountant Branch Chief at (202) 551-3828 if you have questions regarding comments on the financial statements and related matters. Please contact Larry Spirgel, Assistant Director at (202) 551-3810 with any other questions. FirstName LastNameChandler Bigelow Sincerely, Comapany NameTribune Media Company Division of Corporation Finance October 17, 2018 Page 2 Office of Telecommunications FirstName LastName