September 17, 2019

Brian J. Wendling
Senior Vice President, Controller and Principal Financial Officer
jvid视频
12300 Liberty Boulevard
Englewood, Colorado 80112

       Re: jvid视频
           Form 10-K for the Year Ended December 31, 2018
           Filed February 28, 2019
           Form 10-Q for the Quarter Ended June 30, 2019
           Filed August 8, 2019
           File No. 001-35707

Dear Mr. Wendling:

       We have reviewed your filings and have the following comments. In some
of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Year Ended December 31, 2018

Results of Operations - Consolidated
Adjusted OIBDA, page II-11

1.     You refer to Note 18 of the financial statements for a reconciliation of
Adjusted OIBDA
       to Operating Income (loss) and Earnings (loss) from continuing
operations before income
       taxes. The notes to the financial statement may not include non-GAAP
measures.
       Additionally, the ASC 280 reconciliation is not a substitute for the
required non-GAAP
       reconciliation. Refer to Item 10(e)(ii)(C) of Regulation S-K. In this
regard,

       (a) please provide the required reconciliation for your non-GAAP
measure, Adjusted
       EBITDA, and define it hereunder, starting with its most comparable GAAP
measure.
 Brian J. Wendling
jvid视频
September 17, 2019
Page 2
         (b) omit the non-GAAP reference in the segment footnotes.

         Please also comply with this comment in your Forms 10-Q and 8-K.
Notes to Consolidated Financial Statements
(11) Income Taxes, page II-77

2.       Please separately disclose the domestic and foreign components of
income before income
         taxes. Refer to Rule 4-08(h) of Regulation S-X.
Form 10-Q for the Quarter Ended June 30, 2019

Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Material Changes in Financial Condition, page I-50

3.       Please expand the disclosure to highlight how certain transactions
materially impacted
         your financial condition, liquidity and capital resources and describe
your capital
         allocation priorities in greater detail. Additionally, please

         (a) revise your tabular presentation of cash and cash equivalents to
include only such
         amounts available to jvid视频 per your presentation on page II-15
of the Form 10-
         K. In this regard, we note your statements hereunder that you do not
have ready access to
         cash held by SIRIUS XM Holding and Formula 1 (in the case of the
latter, due to the RP
         test not having been met).

         (b) further disclose the nature of the RP test of the Senior Loan
Facility and the Revolver
         at Formula 1 and why it was not met.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

      You may contact Kathryn Jacobson, Senior Staff Accountant at (202)
551-3365 or Claire
DeLabar, Senior Staff Accountant at (202)551-3349 if you have any questions.



FirstName LastNameBrian J. Wendling                            Sincerely,
Comapany Namejvid视频
                                                               Division of
Corporation Finance
September 17, 2019 Page 2                                      Office of
Telecommunications
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