June 28, 2019

Paul W. Orban
Principal Financial Officer
DISH Network Corporation
9601 South Meridian Boulevard
Englewood, Colorado 80112

       Re: DISH Network Coporation
           Registration Statement of Form S-4
           Filed June 6, 2019
           File No. 333-231994

Dear Mr. Orban:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-4

General

1.     We note that this registration statement has been filed for the purpose
of registering the
       DISH Network Class A Common Stock being issued in the merger. The cover
page
       includes the registration of such stock, but could be read to suggest
that the distribution of
       EchoStar BSS Corporation common stock is also being registered. Please
confirm that the
       distribution is not being registered and consider revising your cover
page to clearly
       delineate the transactions covered by the registration statement.
 Paul W. Orban
DISH Network Corporation
June 28, 2019
Page 2
2.    You state that approval by EchoStar stockholders is not required in
connection with the
      pre-closing restructuring, the distribution, or the merger and that
EchoStar stockholders
      are not required to vote on the Transactions. Clarify why EchoStar
determined it needed
      to provide stockholders with an information statement. For example,
explain whether
      EchoStar received written consents authorizing the transactions.

Summary
Accounting Treatment of the Transactions, page 17

3.    Regarding your intended accounting treatment for the transaction where
DISH Network
      will acquire the BSS Business of EchoStar Corporation, please explain to
us the basis
      for your conclusion that the transaction should be considered an asset
purchase. You
      state that "all of the fair value of the gross assets acquired is
concentrated in a group of
      similar identifiable assets." In this regard, provide us a detailed
analysis of how the assets
      listed on page 1 are considered a single asset in accordance with the
guidance in ASC
      805-10-55-5B. Additionally, tell us your consideration of Rule 3-05 and
Article 11 of
      Regulation S-X for this transaction.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

        You may contact Christie Wong, Staff Accountant at (202) 551-3684 or
Robert
Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact Joshua
Shainess, Staff
Attorney at (202) 551-7951 or Celeste Murphy, Legal Branch Chief at (202)
551-3257 with any
other questions.



                                                             Sincerely,
FirstName LastNamePaul W. Orban
                                                             Division of
Corporation Finance
Comapany NameDISH Network Corporation
                                                             Office of
Telecommunications
June 28, 2019 Page 2
cc:       Scott D Miller
FirstName LastName