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VIA EDGAR AND COURIER

Amanda Ravitz

Branch Chief – Legal

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Dear Ms. Ravitz:

On behalf of Live Nation, Inc. (“Live Nation”) we hereby submit responses to the Staff’s comments regarding Live Nation’s Amendment No. 3 to the Registration Statement on Form S-4 (the “Registration Statement”) filed on October 21, 2009 (“Amendment No. 3”), Live Nation’s Annual Report on Form 10-K for the fiscal year ended December 31, 2008, and Live Nation’s Quarterly Report on Form 10-Q for the fiscal quarter ended June 30, 2009, as set forth in the Securities and Exchange Commission’s letter to Michael G. Rowles, Esq., dated October 30, 2009 (the “Comment Letter”). We have also included in this letter, where relevant, responses forwarded to us by counsel to, and/or representatives of, Ticketmaster Entertainment, Inc. (“Ticketmaster Entertainment”) regarding the Staff’s comments to the Registration Statement. Additionally, herewith filed with EDGAR is a complete copy of Amendment No. 4 to the Registration Statement on Form S-4 (“Amendment No. 4”), including exhibits.

We are also providing via courier five copies of Amendment No. 4, including exhibits and two copies of Amendment No. 4 marked to show changes from Amendment No. 3. We are providing courtesy copies of Amendment No. 4 including a version marked for changes, to Claire Erlanger, Linda Cvrkel and John Stickel.

Amendment No. 4 incorporates changes responsive to the comments set forth in the Comment Letter. For your convenience, we have repeated each of the Staff’s comments in bold prior to the response. All references to page numbers and footnotes of the Registration Statement in the responses below each heading are to the pages or footnotes, respectively, in Amendment No. 4. The references to page numbers and footnotes of the Registration Statement in the headings are to Amendment No. 3.

Registration Statement on Form-4

Interests of Ticketmaster Entertainment Directors and Executive Officers in the Merger

Interests of Live Nation Directors and Executive Officers in the Merger, page 105

The Staff is respectfully advised that the table below details by person the pro forma adjustment related to the Live Nation stock options and restricted stock that will vest upon the completion of the Merger.

The Staff is further respectfully advised that a table and related footnotes have been added to footnote (y) on pages 336 to 338 to provide details related to the post-Merger impacts of Messrs. Rapino’s and Azoff’s employment agreements, including the cash bonuses and stock grants. Please see discussion of the accounting for the Front Line put rights in footnote (q) on page 330.

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Note 2. Pro Forma Adjustments, page 326

The Staff is respectfully advised that the “expense for expected recurring impact of salary and bonus adjustments and equity awards to management in connection with the Merger” in footnote (y) on page 336 includes the incremental amounts of salary and other compensation-related items to be incurred due to the agreements with Messrs. Rapino and Azoff, assuming the Merger took place on January 1, 2008. The $12.03 million for the year ended December 31, 2008 includes $2.502 million for Mr. Rapino, representing the incremental expense for the full year 2008, and $9.528 million for Mr. Azoff, representing the incremental expense for the full year 2008.

The Staff is respectfully advised that the pro forma adjustments for 2008 related to the compensation for the Ticketmaster Entertainment Chief Executive Officer, Mr. Azoff, have been updated to include the incremental expense for the twelve months in 2008. The historical financials for Ticketmaster Entertainment include two months of expense related to Mr. Azoff in 2008 as he did not become an employee of Ticketmaster Entertainment until the date of the Front Line acquisition on October 29, 2008 at which time he also became Chief Executive Officer of Ticketmaster Entertainment. The awards and compensation granted to Mr. Azoff in connection with the Merger would not necessarily have been the same compensation and awards that another Chief Executive Officer would have been granted because of the Front Line acquisition.

Live Nation has revised footnote (y) on pages 336 to 338 to provide more information regarding the nature of the amounts included. In addition, the disclosure in Note 1 on page 321 has been revised as noted in the Staff’s comment.

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Footnote (g), page 327

The Staff is respectfully advised that the $5.0 million liability for expected cash payments to management relates to one-time cash bonuses for the Live Nation Chief Executive Officer and the Ticketmaster Entertainment Chief Executive Officer. The disclosure in footnote (g1) and (g2) on page 327 has been revised in response to the Staff’s comment.

Footnote (j), page 327

The Staff is respectfully advised that the restricted stock guarantee to the Ticketmaster Entertainment Chief Executive Officer in connection with the Merger is a modification of a previous restricted stock award issued to him as part of the Front Line acquisition. Ticketmaster Entertainment issued one million restricted shares of Ticketmaster Entertainment common stock to the Ticketmaster Entertainment Chief Executive Officer which generally vest in full on the fifth anniversary of the issuance date. In connection with the Merger, Ticketmaster Entertainment agreed to guarantee a valuation of the one million restricted shares of Ticketmaster Entertainment common stock of no less than $15.0 million upon a specified measurement date. As a result of the guarantee, the award should be classified as a liability. In accordance with SFAS No. 123R, Live Nation has recognized a liability that is equal to the modified award’s modification-date fair value, multiplied by the percentage of the requisite service provided. The modification-date fair value of $18.293 million was calculated as the present value of the $15.0 million guaranteed value plus the estimated fair value related to the potential growth of the underlying restricted common shares in excess of the $15.0 million guarantee. As of June 30, 2009, the Ticketmaster Entertainment Chief Executive Officer has provided approximately eight months of the sixty-month requisite service period. The disclosure in footnote (j) on page 328 has been revised in response to the Staff’s comment to disclose the nature of this amount and how the amount was calculated.

Footnote (l), page 328

The Staff is respectfully advised that the $21.991 million of compensation expense and the resulting increase in liability to be recognized through October 1, 2013 is a result of the conversion of the Ticketmaster Entertainment Series A preferred stock into a Ticketmaster Entertainment note bearing interest at 3% per annum. This change in award from an equity instrument to a liability instrument qualifies as a modification in accordance with SFAS No. 123R. As a result, on the modification date, a liability is recognized equal to the portion of the award attributed to past service multiplied by the award’s fair value. A pro forma adjustment of $13.009 million has been recorded to classify, as a note, the fair value of that portion of the Ticketmaster

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Entertainment Series A preferred stock allocated to the requisite service period that has accreted through June 30, 2009. The difference between the face value of the $35.0 million note and the opening liability of $13.009 million in acquisition accounting, results in remaining unrecognized compensation expense of $21.991 million, which subsequent to the modification, will be recognized over the remaining service period with a resulting increase in the liability on a straight-line basis through October 1, 2013. The disclosure in footnote (l) on page 328 has been revised in response to the Staff’s comment.

Footnote (o), page 329

The Staff is respectfully advised that the $3 million expense for an expected cash payment to management relates to a one-time cash bonus for the Live Nation Chief Executive Officer. Since this is a one-time cash bonus under the terms of his post-Merger employment agreement, Live Nation, as the accounting acquirer, has reflected this as an adjustment to Retained Deficit in the pro formas. Also, upon completion of the Merger, the Ticketmaster Entertainment Chief Executive Officer will receive a one-time cash bonus of $2 million under the terms of his current employment agreement. This adjustment has been recorded in acquisition accounting as it is considered an acquired liability since it is a commitment entered into by Ticketmaster Entertainment prior to the Merger. The disclosure in footnote (o1) on page 329 has been revised in response to the Staff’s comment.

Footnote (q), page 329

The Staff is respectfully advised that the reclassification to redeemable noncontrolling interest relates to the equity instruments in Front Line owned by Mr. Azoff which were modified as part of his new employment agreement to now include a redemption feature. Prior to his employment agreement, 50% of the Front Line common stock, restricted common stock and options owned by Mr. Azoff included a redemption feature. The remaining 50% of the Front Line common stock that did not include a redemption feature was accounted for in noncontrolling interests and the restricted common stock and options that did not include a redemption feature that had not vested and/or been exercised were accounted for in additional paid-in capital. Following the modifications to include a redemption feature in 100% of the equity instruments, it was determined that 50% of the instruments that did not include a redemption feature should now be accounted for as redeemable noncontrolling interests. The $8.266 million reclassification from noncontrolling interests to redeemable noncontrolling interests represents the estimated fair value of the 5,271 Front Line common shares owned by Mr. Azoff that had been previously accounted for in noncontrolling interests. The $1.773 million reclassification from additional paid-in capital to redeemable noncontrolling interests is equal to the inception-to-date compensation expense recognized for the 50% of the restricted common stock and options in Front Line that did not previously include a redemption feature.

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The disclosure in footnote (q) on page 330 has been revised to disclose the amount of the fair value adjustment and the amount related to the reclassification from noncontrolling interests to redeemable noncontrolling interests.

Adjustments to Statements of Operations, Page 329

Footnote (u2), page 332

The Staff is respectfully advised that the elimination in acquisition accounting of short-term and long-term deferred financing fees is disclosed in footnotes (a) and (e), respectively, on page 326. The only impact to interest expense related to these deferred financing fees is the reversal of the amortization expense previously recognized in the pro forma periods as disclosed in footnote (u3).

Footnote (u4), page 332

The Staff is respectfully advised that the disclosure in footnote (u4) on page 334 has been revised in response to the Staff’s comment to disclose the amount of the debt discount associated with the Ticketmaster Entertainment Senior Notes that is being amortized over the term of the notes to interest expense.

Footnote (u5), page 333

Live Nation has revised footnote (u5) on page 334 to explain how the pro forma adjustment was calculated and has revised the adjustment to include the expense for the full year in 2008.

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Footnote (w), page 333

The disclosure in footnote (w) on page 335 has been revised in response to the Staff’s comment.

Footnote (y), page 333

The Staff is respectfully advised that a table and related footnotes have been added to footnote (y) on pages 336 to 338 to provide details related to the post-Merger impacts of the salary and bonus adjustments and equity awards for Messrs. Rapino and Azoff.

Live Nation has revised footnote (y1) on pages 336 to 338 to explain how the pro forma adjustment was calculated and has revised the adjustment to include the expense for the full year in 2008.

The Staff is respectfully advised that Live Nation has revised footnote (u5) on page 334, to provide further detail regarding how the pro forma adjustment related to interest expense was calculated. In addition, Live Nation has also revised footnote (y) on page 336 to remove the amount and discussion of reclassifications from compensation to interest expense. Furthermore, footnote (y1) on pages 336 to 338 has been expanded to disclose the amount of compensation expense related to the Ticketmaster Entertainment Note.

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Audited Financial Statements of Ticketmaster Entertainment for the year ended December 31, 2008

Note 2. Summary of Significant Accounting Policies

Non-Controlling Interests in Consolidated Financial Statements

The Staff is respectfully advised that Ticketmaster Entertainment will file amendments to its quarterly reports on Form 10-Q for the quarters ended March 31, 2009 and June 30, 2009 to correct the classification of noncontrolling interests prior to the planned effectiveness of the Registration Statement.

Live Nation Financial Statements for the years ended December 31, 2008, 2007 and 2006

Note 6. Investments

The Staff is respectfully advised that Live Nation will revise future filings, as appropriate, to include disclosure of the nature and amount for differences that occur in accounting for its equity investments.

Exhibit 8.1

The disclosure in the second paragraph on page 1 of the opinion, as well as the disclosure in assumption paragraph number 3 on page 2 of the opinion and assumption paragraph number 2 on page 3 of the opinion, have been revised in response to the Staff’s comment.

The disclosure in assumption paragraph number 1 on page 2 of the opinion has been revised to delete the word “valid” in response to the Staff’s comment.

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The final clause in assumption paragraph number 2 on page 2 of the opinion has been deleted in response to the Staff’s comment.

Assumption paragraph number 1 has been revised in response to the Staff’s comment.

The final paragraph of the opinion has been revised in response to the Staff’s comment.

Exhibit 8.2

The disclosure in the second paragraph of the opinion has been revised in response to the Staff’s comment.

The assumption referenced in the Staff’s comment has been deleted in response to the Staff’s comment.

The disclosure in the final paragraph of the opinion has been revised in response to the Staff’s comment.

Exhibit 99.6

The consent has been revised in response to the Staff’s comment. The revised and updated consent is filed as Exhibit 99.6 to the Registration Statement.

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Live Nation acknowledges that:

Should you have any questions regarding the foregoing, please do not hesitate to contact me at (213) 891-8680.