September 12, 2018

Gunnar Wiedenfels
Chief Financial Officer
Discovery, Inc.
One Discovery Place
Silver Spring, MD 20910

       Re: Discovery, Inc.
           Form 10-K for the Year Ended December 31, 2017
           Filed February 28, 2018
           Form 10-Q for the Quarter Ended June 30, 2018
           Filed August 8, 2018
           File No. 001-34177

Dear Mr. Wiedenfels:

       We have reviewed your filing 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-Q for the Quarterly Period Ended June 30, 2018

Distribution, page 39

1.    Please help us understand why your video on demand ("VOD") offerings
match the
      programs that are airing on your linear network. Tell us if there are
circumstances in
      which existing content is delivered at the outset of the distribution
arrangements.
2.    We note your disclosure on page 41 that most of your distribution
contracts are licenses of
      functional intellectual property. Please help us understand your basis
for recognizing
      revenue for fixed price contracts over the contract term.
3.    We note that certain distribution contracts have minimum guarantees.
Please explain the
 Gunnar Wiedenfels
Discovery, Inc.
September 12, 2018
Page 2
      types of guarantees provided and clarify your pattern of revenue
recognition. Refer to
      ASC 606-10-50-19.
Advertising, page 40

4.    We note certain advertising contracts have audience level guarantees and
revenues are
      deferred until the guaranteed audience level is delivered or the rights
associated with the
      guarantee lapse. Please help us understand the terms of the guarantee. It
is unclear if the
      guarantee relates to individual episodes or a program season. In
addition, please clarify if
      these guarantees are treated as variable consideration in determining
your transaction
      price. Refer to ASC 606-10-32-5 and 606-10-50-20.
Multiple Performance Obligations, page 40

5.    Please tell us if your arrangements include promises to provide content
libraries. If so,
      please tell us how you considered if existing content and new content
represent separate
      performance obligations and explain how you considered judgments in
determining both
      amounts allocated to and the timing of satisfaction of each performance
obligation. Refer
      to ASC 606-10-50-12 and ASC 606-10-50-17.
        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
Robert Littlepage, Accountant Branch Chief at (202)551-3361 if you have
questions regarding
comments on the financial statements and related matters. Please contact
William Mastrianna,
Staff Attorney at (202) 551-3778 or Celeste Murphy, Legal Branch Chief at (202)
551-3257 with
any other questions.



                                                            Sincerely,
FirstName LastNameGunnar Wiedenfels
                                                            Division of
Corporation Finance
Comapany NameDiscovery, Inc.
                                                            Office of
Telecommunications
September 12, 2018 Page 2
cc:       Stephanie Marks
FirstName LastName