January 29, 2020
Via E-mail

Igor Kirman, Esq.
Wachtell, Lipton, Rosen & Katz
51 West 52nd Street
New York, NY 10019


       Re:     TEGNA Inc.
               Definitive Additional Materials on Schedule 14A
               Filed January 21, 2020
               File No. 001-06961

Dear Mr. Kirman:

       We have reviewed the above-captioned 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 this letter by amending the referenced filings and/or
by providing the
requested information. After reviewing any amendment to the filings and any
information
provided in response to these comments, we may have additional comments.

       If you do not believe our comments apply to your facts and
circumstances, and/or do not
believe an amendment is appropriate, please tell us why in a written response.

Letter to Shareholders

1. 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
   your statement that Mr. Kim's prior business and board service raises
concerns including a
   "track record of endorsing and executing corporate actions in favor of his
own interests to the
   detriment of other shareholders, as well as a dismissive attitude toward the
perspectives of
   other directors." In this regard, note that the factual foundation for such
assertion must be
   reasonable. Refer to Rule 14a-9.

2. On a related note, please provide us supplemental support for your
disclosure that "[m]any
   who know [Mr. Kim] well commented on his track record..."
 Igor Kirman, Esq.
Wachtell, Lipton, Rosen & Katz
January 29, 2020
Page 2

3. We note your assertion that Mr. Kim and Standard General have a conflict of
interest arising
   out of Mr. Kim's investments in Mediaco Holding, which you state is a
competitor of
   TEGNA. It is our understanding that Mediaco is primarily in the business of
operating radio
   stations. With a view toward revised disclosure in your next filings, please
tell us the basis
   for your assertion that Mediaco is a competitor of TEGNA given TEGNA's focus
on
   television broadcasting. Your response should include support for your
belief that a conflict
   of interest exists.

4. It appears Standard General has publicly committed not to make any new
investment in TV
   stations without first offering the opportunity to TEGNA. Accordingly,
please confirm that
   in future filings you will remove your discussion regarding conflicts of
interest with respect
   to acquisitions of TV broadcasting, or revise to include disclosure of this
commitment.

5. 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. Provide support for the following:

       That the company "...has also been successful in generating durable
subscription
       revenues in recent years and [you] anticipate another strong year ahead.
Due to the
       current subscription fee repricing cycle, [you] expect to generate at
least mid-twenties
       percentage growth in 2020."
       That your recent acquisitions have added "significant revenues, EBITDA,
and free cash
       flow..."

Fact Sheet

6. Refer to the section in your fact sheet filed as soliciting material and
posted on your website
   highlighting projections for "2020 and beyond." Disclose the basis for the
following
   predictions:

       Projected subscription revenue growth;
       Projected political revenue;
       Free cash flow as a percentage of revenue; and
       Projected leverage.

7. Provide us with the methodology used to determine the parameters for and
members of the
   peer set referenced in footnote 1 to the fact sheet.


                                               *   *   *
 Igor Kirman, Esq.
Wachtell, Lipton, Rosen & Katz
January 29, 2020
Page 3

        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

      Please direct any questions to me at (202) 551-7951. You may also contact
Daniel
Duchovny, Special Counsel, at (202) 551-3619.


                                                            Sincerely,

                                                            /s/ Joshua Shainess

                                                            Joshua Shainess
                                                            Special Counsel
                                                            Office of Mergers
and Acquisitions