February 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.
              Soliciting Materials filed pursuant to Rule 14a-12
              Filed February 20, 2020 by Standard General L.P., et al.
              File No. 001-06961

Dear Mr. de Wied:

       We have reviewed the above-captioned filing and your response to our
comment letter
dated February 14, 2020. We have the following comments.

1. Refer to comment 1 in our prior comment letter and your response dated
February 14, 2020.
   We note your undertaking to provide disclosure addressing how the ownership,
or lack
   thereof, of TEGNA shares by your nominees will affect the alignment of
interests of those
   nominees with TEGNA shareholders. Please confirm again you will do so in
future filings.

2. With a view toward revised disclosure in future filings, tell us how you
determined that
   TEGNA's Board is "entrenched." We note that TEGNA has added six new
independent
   directors over the past five years.

3. Provide us with support for your characterization of TEGNA as a "perennial
underachiever"
   and for your assertion that "TEGNA has campaigned energetically - and
wastefully - in
   defense of a long-term track record of underperformance." For example, tell
us, with a view
   toward additional disclosure in future filings, against what baseline you
are comparing to.

4. Please refer to the following assertion: "the incumbent TEGNA Board and
management team
   spent in excess of $6 million of shareholders' money in Q4 2019 alone--and
are poised to
   spend millions more in 2020..." Provide us with the factual foundation in
support of the
   cited assertion and advise us how Standard General became aware of TEGNA's
future
   spending.

5. Provide the basis for your assertion that "[s]hareholders deserve a detailed
accounting of
   exactly how this money is being spent." For example, address whether any
requirement
   under federal or state law applies to this assertion. Additionally, this
statement seems to
   imply that shareholders currently do not have the means to consider TEGNA's
spending. In
 Warren S. de Wied, Esq.
Fried, Frank, Harris, Shriver & Jacobson LLP
February 24, 2020
Page 2

    your response, clarify your belief as to whether such spending is reflected
in TEGNA's
    financial statements.

6. As a foundation for one of your assertions, you refer to "Apollo's interest
in acquiring
   TEGNA..." It is our understanding that neither TEGNA nor Apollo have
followed through
   with a proposal for such a transaction. In future filings, please provide
this additional context
   when referencing TEGNA's discussions with Apollo.

                                               *   *   *

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


                                                             Sincerely,

                                                             /s/ Joshua
Shainess

                                                             Joshua Shainess
                                                             Special Counsel
                                                             Office of Mergers
and Acquisitions