Corre Partners Management, LLC
1370 Avenue of the Americas, 29th Floor
New York, New York 10019
December 22, 2011
VIA FACSIMILE AND MAIL
Daniel F. Duchovny, Esq.
Special Counsel, Office of Mergers and Acquisitions
Divisions of Corporation Finance
United States Securities and Exchange Commission
Washington, D.C.
20549-3628
Facsimile: (202) 772-9203
| Re: | Emmis Communications Corporation |
Schedule 13D filed by Corre Partners Management, LLC
Filed December 16, 2011
File No. 005-43521
Dear Mr. Duchovny:
Corre Partners Management, LLC (“Corre”) is delivering this letter in response to your letter of December 20, 2011, addressed to Mr. James Moloney of Gibson, Dunn & Crutcher LLP.
To address the comments raised in your letter, Corre is in the process of preparing an amendment to its Schedule 13D which was filed on December 16, 2011. We expect this amendment will be filed today or on December 23, 2011.
In addition, as requested in your letter, Corre hereby acknowledges the following:
| 1. | As filing person, it is responsible for the adequacy and accuracy of the disclosure in its filing; |
| 2. | Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| 3. | Corre may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
| Sincerely, |
| Corre Partners Management, LLC |
|
/s/ Eric Soderlund |
| By: Eric Soderlund, Managing Member |