1.

In your discussion, you cite multiple various factors as impacting your results of operations but provide no quantification of the contribution of each factor to the material changes in the various line items discussed. For instance, in the first paragraph of your discussion of consolidated operating revenue and expense on page 17 you attributed an increase in revenue to three factors, each unquantified. Neither is the impact of an offsetting factor, reduced political advertising revenue, quantified. Please see the guidance provided by Section III.D of Release 33-6835 and, as applicable, revise throughout to quantify the impact of each material factor discussed when your results are impacted by two or more factors. In addition, you should remove vague terms such as “primarily” in favor of specific quantifications.

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2.

Moreover, we note that your discussion of year to year comparative changes on a consolidated basis contains a limited general discussion of consolidated operating expense as a category. Please revise in accordance with Instruction 4 to Item 303(a) of Regulations S-K to separately discuss material changes in consolidated financial statement line items such as: consolidated costs of sales and operating expense; consolidated selling, general and administrative expenses; consolidated amortization of intangibles assets; and consolidated facility consolidation and net assets (gains) and impairment charges.

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3.	We note that the operations of your Digital reportable segment primarily consist of Cars.com and CareerBuilder business units. We also note the significant impact of the recent acquisition of Cars.com on revenues. In order to help us understand how you applied the guidance in FASB ASC 280 in identifying your operating and reportable segments, please provide us with the following information:

•	Provide your organization chart which identifies the positions, roles, or functions that report directly to your chief operating decisions maker (“CODM”) and senior management team;

•	Tell us the title and describe the role of your CODM and each of the individuals who report to the CODM;

•	Identify for us each of the operating segments you have determined in accordance with FASB ASC 280;

•	Identify and describe the role of each of your segment managers;

•	Tell us how often the CODM meets with his/her direct reports, the financial information the CODM reviews to prepare for those meetings, the financial information discussed in those meetings, and who attends those meetings;

•	Describe the information regularly provided to the CODM and tell us how frequent it is prepared;

•	Describe the information regularly provided to the Board of Directors and tell us how frequent it is prepared;

•	Describe the information about Cars.com and CareerBuilders product offerings that are provided to the CODM, tell us whether there are managers accountable for the product offerings, and if so, tell us to whom they accountable;

•	Explain how budgets are prepared, who approves the budget at each step of the process, the level of detail discussed at each step, and the level at which the CODM makes changes to the budget;

•	Describe the level of detail communicated to the CODM when actual results differ from budgets and who is involved in meeting with the CODM to discuss budget-to-actual variances; and,

•	Describe the basis for determining the compensation of the individuals that report to the CODM.

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•	Decisions on capital allocation:

•	Annual budgets, including capital budgets:

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President, TEGNA Media: Responsible for overseeing the Company’s 46 television stations (including those serviced by TEGNA). TEGNA Media is the largest independent operator of major network affiliates in the top 25 markets and covers approximately one-third of all television households nationwide. The President of Media is responsible for planning, developing and executing the Media Segment’s short-term and long-term strategic goals.

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President, TEGNA Digital: Responsible for overseeing the Company’s digital portfolio including Cars.com, CareerBuilder, G/O Digital, Cofactor, and various joint ventures within TEGNA Digital. The President of Digital is responsible for planning, developing and executing the Digital Segment’s short-term and long-term strategic goals. This position is also responsible for the development and implementation of online strategies, partnerships, and investment initiatives across all of TEGNA’s digital platforms.

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Quarterly forecast updates: On a monthly basis quarterly revenue and profit forecast updates are prepared using the actuals for the most recently closed month, plus estimates from the segment managers for their respective businesses for the remaining months in the quarter. These estimates are prepared on a consolidated and operating segment basis. The operating segment detail is the same presentation that is used in our earnings release and Form 10-Q and Form 10-K filings. This presentation reflects allocations to the operating segments of certain expense items such as stock-based compensation, our executive bonus pool, technology costs and intangible amortization. Comparisons are made between the last estimate, the prior year quarter and budget.  Certain business unit (e.g., Cars.com, CareerBuilder, G/O Digital, CoFactor and certain TV Station groupings) revenue and profit financial detail is also included within the quarterly forecast update as supplementary information; the detail is provided solely to facilitate isolating and explaining variances.

•	Segment operating results: At the conclusion of the quarter, quarterly and year-to-date segment operating results for the Media and Digital segments are prepared which include operating revenues, operating expenses (with allocations), operating income and adjusted EBITDA. These are

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Board of Directors monthly financial update presentation: These monthly updates generally include financial information on a consolidated basis (revenue, operating income, balance sheet, and cash flow information). Income statement comparisons are made to budget and prior year. In addition, supplementary revenue information is provided for the different business units within our Digital Segment (e.g., Cars.com, CareerBuilder, G/O Digital, and Cofactor), and supplementary Media Segment revenues are also presented by revenue type (e.g., Core, Political, Retransmission, and Digital). No segment operating profit (or any level of operating profit below the operating segment level) is included in the monthly financial update presentations provided to the Board of Directors.

•	Monthly financial package (presented on a monthly, quarterly, and year-to-date basis, along with prior-year comparisons and comparisons to our budgeted expectations) which includes the following information:

◦	Consolidated operating results which are presented on a U.S. GAAP, Non-GAAP (which excludes certain special items), and pro-forma (in cases where there was a large acquisition or disposition) basis;

◦	Media Segment and Digital Segment operating results; *

◦	Corporate operating costs;

◦	Each television station (46 stations) operating results (revenues and direct operating expenses); *

◦	Each business unit within Digital Segment (Cars.com, CareerBuilder, G/O Digital and Cofactor) revenue and direct operating expenses; *

•	Monthly revenue trends presented on a consolidated, Media, and Digital basis.

•	Quarterly Investor Relations binder which includes the schedules summarized above and also provides various other financial information prepared at a consolidated or operating segment level (including balance sheet, cash flow, special items summary, and leverage ratio).

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Monthly Media and Digital segment reports from the Presidents of these business segments (e.g., segment managers). These monthly segment reports are narrative summaries with a focus on providing an update on various strategic initiatives. In addition, financial information with comparisons to the prior year and budget is provided. The Media monthly report provides financial information at the segment level. The Digital monthly report provides financial information by business unit (e.g., Cars.com, CareerBuilder, G/O Digital, and Cofactor). The Digital financial information by business unit does not include fully allocated expenses.

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•	The nature and responsibility of the position.

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The achievement of key performance indicators (KPIs), both historically and in the immediately prior year. KPI goals are weighted and include several performance measures including, product, personnel, and financial performance goals. The financial performance goals are at the operating segment level for the Media segment manager. Financial performance goals for the Digital segment manager are at both the operating segment and business unit levels.

•	Internal pay equity among positions.

•	Comparative market data.

•	The nature and responsibility of the position.

•	Internal pay equity among positions.

•	Comparative market data.

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•	The Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•	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

•	The Company 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.

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