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