United States securities and exchange commission logo August 5, 2020 Craig D. Fischer Chief Financial Officer Hemisphere Media Group, Inc. 4000 Ponce de Leon Boulevard Suite 650 Coral Gables, FL 33146 Re: Hemisphere Media Group, Inc. Form 10-K for the Year Ended December 31, 2019 Filed March 9, 2020 File No. 001-35886 Dear Mr. Fischer: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. 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. Form 10-K for the Year Ended December 31, 2019 Notes to Consolidated Financial Statements Note 7. Equity Investments, page F-26 1. Considering that you hold variable interests in certain VIEs but are not their respective primary beneficiary, please disclose the methodology for your determination, including significant judgments and assumptions, as well as other required information pursuant to ASC 810-10-50-5A and advise us in detail. Craig D. Fischer Hemisphere Media Group, Inc. August 5, 2020 Page 2 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 Kathryn Jacobson, Senior Staff Accountant at (2002) 551-3365 or Robert Littlepage, Accountant Branch Chief at (202) 551-3361with any questions. FirstName LastNameCraig D. Fischer Sincerely, Comapany NameHemisphere Media Group, Inc. Division of Corporation Finance August 5, 2020 Page 2 Office of Technology FirstName LastName