November 30, 2018

Sean Gamble
Chief Financial Officer
Cinemark Holdings, Inc.
3900 Dallas Parkway Suite 500
Plano, Texas 75093

       Re: Cinemark Holdings, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed on February 23, 2018
           Form 10-Q for the Quarter Ended September 30, 2018
           Filed on November 2, 2018
           File No. 001-33401

Dear Mr. Gamble:

       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 Quarter Ended September 30, 2018

Notes to the condensed consolidated financial statements
3. Revenue Recognition, page 10

1.    Please disclose the amount by which each financial statement line item is
affected in the
      current reporting period by ASC 606 as compared with the guidance that
was in effect
      before the change in accordance with ASC 606-10-65-1(i), including an
explanation of the
      reasons for the significant changes identified.
2.    We note you adopted ASC 606 under the modified retrospective method
effective January
      1, 2018. In this regard, please disclose whether you have applied the
guidance to all
      contracts at the date of initial application or only to contracts that
are not completed at the
      date of initial application.
 Sean Gamble
Cinemark Holdings, Inc.
November 30, 2018
Page 2
3.       We note from your disclosures on page 10, the adoption of ASC 606
resulted in an
         increase in other revenues due to the change in amortization
methodology for deferred
         revenue - NCM from units of revenue method to straight-line basis for
the term of the
         ESA. Please explain to us in greater detail why amortization of
deferred revenue
         associated with the ESA and Common Unit Adjustment on a straight-line
basis is
         appropriate and a reasonable measure of progress in accordance with
ASC 606. Please
         revise your footnote to provide an explanation of why the method used
provides a faithful
         depiction of the transfer of goods or services as required by ASC
606-10-50-18b.
       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 Aamira Chaudhry at 202-551-3389 or Jean Yu at
202-551-3305 with
any questions.



FirstName LastNameSean Gamble                                Sincerely,
Comapany NameCinemark Holdings, Inc.
                                                             Division of
Corporation Finance
November 30, 2018 Page 2                                     Office of
Transportation and Leisure
FirstName LastName