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                              January 4, 2021

       Suzanne S. Bettman
       General Counsel
       LSC Communications, Inc.
       191 N. Wacker Drive, Suite 1400
       Chicago, Illinois 60606

                                                        Re: LSC Communications,
Inc.
                                                            Form 10-K for the
Year Ended December 31, 2019
                                                            Form 10-Q for the
Quarter Ended September 30, 2020
                                                            File No. 001-37729

       Dear Ms. Bettman:

              We have reviewed your December 14, 2020 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       December 1, 2020 letter.

       Form 10-Q for the Quarter Ended September 30, 2020

       Financial Statements
       Notes to Condensed Consolidated Financial Statements (Unaudited)
       Note 8. Restructuring, Impairment, and Other Charges
       Goodwill, page 31

   1.                                                   We note your response
to prior comment 2 that there was no further economic decline and
                                                        no further decline in
the company's stock price during the third quarter. However, we note
                                                        that your market
capitalization decreased in third quarter 2020 with the decline of your
                                                        stock price from June
30, 2020 of $0.06 to $0.04 at September 30, 2020. In addition, we
                                                        note larger losses in
the third quarter of 2020 than in the second quarter of 2020 as well as
                                                        increased negative cash
flows. Please explain your consideration of these facts and why
                                                        these did not result in
additional impairment testing as of September 30, 2020.
 Suzanne S. Bettman
LSC Communications, Inc.
January 4, 2021
Page 2
Form 10-K for the Year Ended December 31, 2019
Financial Statements
Notes to Consolidated Financial Statements
Note 2. Significant Accounting Policies
Revenue Recognition, page F-10

2.       We note your response to prior comment 1. Please tell us whether the
revenues associated
         with such arrangements are material. If so, please expand your revenue
footnote to include
         more robust detail similar to that provided in your response.
       You may contact Heather Clark at 202-551-3624 or Jean Yu at 202-551-3305
if you have
any questions.



FirstName LastNameSuzanne S. Bettman                         Sincerely,
Comapany NameLSC Communications, Inc.
                                                             Division of
Corporation Finance
January 4, 2021 Page 2                                       Office of
Manufacturing
FirstName LastName