December 17, 2018 Roland A. Caputo Chief Financial Officer New York Times Company 620 Eighth Avenue New York, New York 10018 Re: New York Times Company Form 10-K for the Fiscal Year Ended December 31, 2017 Filed February 27, 2018 File No. 001-05837 Dear Mr. Caputo: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Transportation and Leisure