UNITED STATES
                                  SECURITIES AND EXCHANGE COMMISSION
                                               WASHINGTON, D.C. 20549


     DIVISION OF
CORPORATION FINANCE


                                                                April 4, 2019

  By E-Mail

  Andrew M. Freedman, Esq.
  Olshan Frome Wolosky LLP
  1325 Avenue of the Americas
  New York, NY 10019

          Re:     Gannett Co., Inc.
                  Definitive Additional Materials on Schedule 14A filed by MNG
Enterprises,
                    Inc., et. al.
                  Filed on April 2, 2019
                  File No. 001-36874

  Dear Mr. Freedman:

        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.

  Definitive Additional Soliciting Materials
  Item 1. Press Release dated April 2, 2019

  1.      We note your references to historical financial results without the
clarification you made
          in your proxy statement in response to comment 6 in our March 21,
2019 letter. Please
          revise.

  2.      Each statement or assertion of opinion or belief must be clearly
characterized as such,
          and a reasonable factual basis must exist for each such opinion or
belief. Support for
          opinions or beliefs should be self-evident, disclosed in the proxy
statement or provided to
          the staff on a supplemental basis. With a view toward revised
disclosure, provide support
          for your statement that you are offering "speed and certainty" in
connection with your
          offer.

  3.      With a view toward revised disclosure, state whether Oaktree is
willing to finance your
          offer, in part or in full, or whether Oaktree is solely evaluating
your credit worthiness for
          purposes of the proposed transaction.

  4.      We note your references to the Gannett board as "delusional" and to
Gannett offering
          "just a bunch of misleading statistics." Note that you must avoid
issuing statements that
          directly or indirectly impugn the character, integrity or personal
reputation or make
          charges of illegal, improper or immoral conduct without factual
foundation. Provide us
          supplementally, or disclose, the factual foundation for the assertion
referenced above. In
 Andrew M. Freedman
Olshan Frome Wolosky LLP
April 4, 2019
Page 2

      this regard, note that the factual foundation for such assertion must be
reasonable. Refer
      to Rule 14a-9.

5.    We note your disclosure that "Not voting is the same as voting against
the transaction."
      Please revise your disclosure to clarify it. For example, explain (i) why
a vote on the
      election of directors is related to a vote on a proposed transaction, and
(ii) given the
      plurality voting standard applicable to the upcoming election of
directors, how not voting
      will have an impact on the election of directors.

      Please direct any questions to me at (202) 551-3619.

                                                           Sincerely,

                                                           /s/ Daniel F.
Duchovny
                                                           Daniel F. Duchovny
                                                           Special Counsel
                                                           Office of Mergers
and Acquisitions