September 17, 2019

Brian Wendling
Senior Vice President, Controller and Principal Financial Officer
GCI LIBERTY, INC.
12300 Liberty Boulevard
Englewood, CO 80112

       Re: GCI LIBERTY, INC.
           Form 10-K for the Year Ended December 31, 2018
           Filed February 28, 2019
           File No. 001-38385

Dear Mr. Wendling:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 10-K for the Year Ended December 31, 2018

Results of Operations - Consolidated
Adjusted OIBDA, page II-8

1.     You refer to Note 16 of the financial statements for a reconciliation of
Adjusted OIBDA
       to Operating Income (loss) and Earnings (loss) from continuing
operations before income
       taxes. The notes to the financial statement may not include non-GAAP
measures.
       Additionally, the ASC 280 reconciliation is not a substitute for the
required non-GAAP
       reconciliation. Refer to Item 10(e)(ii)(C) of Regulation S-K. In this
regard, please
       - provide the required reconciliation for your non-GAAP measure,
Adjusted EBITDA, and
       define it hereunder, starting with its most comparable GAAP measure.
       - omit the non-GAAP reference in the segment footnotes.

       Please also comply with this comment in your Forms 10-Q and 8-K.
 Brian Wendling
GCI LIBERTY, INC.
September 17, 2019
Page 2

       In closing, 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 Claire DeLabar, Senior Staff Accountant at (202)
551-3349 or Kathryn
Jacobson, Senior Staff Accountant at (202) 551-3365 with any questions.



FirstName LastNameBrian Wendling                          Sincerely,
Comapany NameGCI LIBERTY, INC.
                                                          Division of
Corporation Finance
September 17, 2019 Page 2                                 Office of
Telecommunications
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