Melissa Walsh

Stephen Krikorian

AMC Networks Inc.

Form 10-K for the Fiscal Year Ended December 31, 2024

File No. 001-35106

We note your disclosure that most of your leases do not provide an implicit rate, so you use your incremental borrowing rate. Tell us how your determination of the discount rate for your leases complies with the guidance in ASC 842-20-30-3. That is, even though your operating leases do not provide an implicit rate, explain whether the rates implicit in any of your leases are readily determinable from information provided in the lease.

You indicate that the chief operating decision maker (“CODM”) uses segment adjusted operating income (“AOI”) as the measure of profit or loss for your operating segments. We note you also present operating income for each reportable segment. Tell us whether the CODM receives operating income for each reportable segment and how it is used. If the CODM uses more than one measure of segment profit or loss, such as operating income and AOI, explain what consideration you gave to the guidance in ASC 280-10-50-28A, which indicates that at least one of the reported segment profit or loss measures shall be that which management believes is determined in accordance with the measurement principles most consistent with those used in measuring the corresponding amounts in the consolidated financial statements. In this regard, certain disclosures are required for each reported measure of a segment’s profit or loss. See ASC 280-10-50-28C.

Revenues, net from external customers

Subscription

Advertising

Content licensing and other

Inter-segment revenues (Content licensing and other) ^(a)

Reconciliation of revenue

Elimination of inter-segment revenues ^(a)

Total consolidated revenues, net

Less: ^(b)

Content expenses

Marketing, research, and advertising sales expenses

Other ^(c)

Segment adjusted operating income

Reconciliation of total segment adjusted operating income

Elimination of inter-segment profits

Unallocated corporate overhead costs ^(d)

Share-based compensation expenses

Depreciation and amortization

Impairment and other charges

Restructuring and other related charges

Cloud computing amortization

Majority-owned equity investees AOI

Operating income (loss)

Other income (expense):

Interest expense

Interest income

Loss on extinguishment of debt, net

Miscellaneous, net

Income (loss) from operations before income taxes

Inter-segment revenues primarily relate to Domestic Operations content licensing sales to International, as well as services performed by AMCNI on behalf of businesses within the Domestic Operations segment.

The significant expense categories and amounts align with the segment-level information that is regularly provided to the CODM.

Other for each reportable segment primarily includes employee-related costs, information technology costs, professional services expenses, occupancy expenses, certain overhead expenses and the Company’s proportionate share of adjusted operating income (loss) from majority-owned equity method investees.

Unallocated corporate overhead costs include costs such as executive salaries and benefits and costs of maintaining corporate headquarters, facilities and common support functions.

Revenues, net

Operating Income (Loss)

Adjusted Operating Income

Adjusted Operating Income (Loss) is a non-GAAP financial measure. See the “Non-GAAP Financial Measures” section on page 58 for additional information, including our definition and our use of this non-GAAP financial measure, and for a reconciliation to its most comparable GAAP financial measure.

Revenues, net

Technical and operating expenses (excluding depreciation and amortization) ^(a)

Selling, general and administrative expenses ^(b)

Technical and operating expenses excludes cloud computing amortization

Selling, general and administrative expenses excludes share-based compensation expenses and cloud computing amortization, and are presented net of inter-segment eliminations

Income (loss) from operations before income taxes

Other income (expense):

Interest expense

Interest income

Loss on extinguishment of debt, net

Miscellaneous, net

Operating income (loss)

Share-based compensation expenses

Depreciation and amortization

Impairment and other charges

Restructuring and other related charges

Cloud computing amortization

Majority owned equity investees AOI

Adjusted operating income (loss)

Please revise future filings to reconcile the total of the reportable segments’ amount for each measure of profit or loss to consolidated income before income taxes. Refer to ASC 280-10-50-30(b) and ASC 280-10-50-28C. In this regard, the reconciliation should include a single amount for the subtotal of the reportable segments’ measures of profit or loss with a reconciliation of that amount to consolidated income before income taxes. The segment note currently separates reconciling items among the reportable segments and Corporate / Inter-segment eliminations category and results in the presentation of an additional non-GAAP measure of consolidated adjusted operating income.

Kristin A. Dolan, Chief Executive Officer

Sal Romanello, Executive Vice President and General Counsel

(AMC Networks Inc.)

Robert W. Downes, Esq.

(Sullivan & Cromwell LLP)

Daniel Meagher

(KPMG LLP)