April 24, 2020
Via E-mail

Warren S. de Wied, Esq.
Fried, Frank, Harris, Shriver & Jacobson LLP
One New York Plaza
New York, NY 10004

       Re:     TEGNA Inc.
               Definitive Additional Materials on Schedule 14A
               Filed April 13, 2020 by Standard General L.P., et al.
               File No. 001-06961

Dear Mr. de Wied:

     We have reviewed the above-captioned filing and have the following

DFAN14A filed April 13, 2020

1. We note your statement on page 21 of the investor presentation that "TEGNA
has 2x the
   number of employees per station compared to peers." Please revise this
portion of the
   investor presentation, and anywhere else you use this figure, to provide
context by disclosing
   the size of the markets that TEGNA operates in as compared to the markets of
the referenced

2. Refer to pages 22 and 24 of your investor presentation. With respect to your
assertions that
   (i) TEGNA's EBITDA margins have declined and (ii) TEGNA's free cash flow
conversion is
   worst among peers, please tell us how your reliance on pro forma information
from 2016 and
   2017 is relevant given TEGNA's transformation in late 2017 to a pure-play

3. We note your comparison of the Company's market capitalization to the
aggregate purchase
   prices that TEGNA paid for stations on page 45. Revise this section to
disclose the date used
   for purposes of using TEGNA's stock price to calculate market
capitalization. If the date
   used reflects the broader market decline resulting from the COVID-19
pandemic, disclose
   this fact, and explain why you believe the use of such a date is

4. Refer to page 47 of the presentation, where you label the events on the
timeline "TEGNA
   Entrenchment Actions." Absent disclosure of reasonable factual support for
the assertion
   that these actions were taken for the purpose of board entrenchment, please
revise the
   presentation to remove the characterization of these events as "entrenchment
 Warren S. de Wied, Esq.
Fried, Frank, Harris, Shriver & Jacobson LLP
April 24, 2020
Page 2

5. Tell us the basis for your assertion on page 48 that "[i]t does not appear
that the Company
   was willing to engage these suitors during the whole of 2019." We understand
that three of
   the four suitors that made offers in 2020 did not express interest in 2019,
and that one suitor
   proposed a transaction in 2019 that would not have resulted in a change of
control of the
   company, as distinguished from the offer it made in 2020.

6. As requested in our letter dated April 16, 2020, please remove statements
about TEGNA's
   board requiring an "all cash offer," as we are unable to locate support for
such statements.

                                               *   *   *

      Please direct any questions to me at (202) 551-7951. You may also contact
Duchovny, Special Counsel, at (202) 551-3619.


                                                             /s/ Joshua

                                                             Joshua Shainess
                                                             Special Counsel
                                                             Office of Mergers
and Acquisitions