VIA EDGAR

August 18, 2020

Ms. Joyce Sweeney, Senior Staff Accountant

Ms. Kathleen Collins, Accounting Branch Chief

Division of Corporation Finance

Office of Technology

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Dear Ms. Sweeney and Ms. Collins:

We are writing this letter in response to the comment letter of the Staff of the Securities and Exchange Commission (the “Staff” of the “SEC”) dated July 21, 2020 relating to Comcast Corporation’s Form 10-K for the year ended December 31, 2019 and Form 10-Q for the quarter ended March 31, 2020. For your convenience, we have reproduced the Staff’s comment preceding our response below. Please let us know if you have any questions or if we can provide additional information or otherwise be of assistance in expediting the review process.

Form 10-Q for the Quarter Ended March 31, 2020

Guarantee Structure, page 32

such amounts as of December 31, 2019 as required by Rule 13-01(a)(4)(v), and clarify whether those amounts, or any other amounts disclosed pursuant to Rule 13-01(a)(4), represent current or non-current assets and liabilities.

Response

Comcast Corporation (“Comcast”) has a series of guarantee structures in place relating to its debt and the debt outstanding at certain of its consolidated subsidiaries. NBCUniversal Media, LLC (“NBCUniversal”), Comcast Cable Communications, LLC (“Comcast Cable”) and Comcast Holdings Corporation (“Comcast Holdings”) are each consolidated subsidiaries subject to the periodic reporting requirements of the SEC, and beginning with our Form 10-Q for the quarter ended March 31, 2020 (the “First Quarter 10-Q”), we have included the disclosures specified in Rule 13-01 of Regulation S-X in satisfaction of these requirements.

Comcast, NBCUniversal and Comcast Cable fully and unconditionally, jointly and severally, guarantee each other’s debt securities and NBCUniversal and Comcast Cable also guarantee other borrowings of Comcast. For purposes of our disclosures under Rule 13-01, Comcast, NBCUniversal and Comcast Cable comprise an “Obligor Group” (as such term is used in SEC Release No. 33-10762, “Financial Disclosures about Guarantors and Issuers of Guaranteed Securities and Affiliates Whose Securities Collateralize a Registrant’s Securities”). Comcast also provides a full and unconditional guarantee of certain debt securities issued by Comcast Holdings and together, these two entities comprise a separate “Obligor Group.”

As discussed during our July 9, 2020 call with the Staff, we performed a detailed analysis and concluded that the full summarized financial information specified in Rule 13-01(a)(4) for each Obligor Group would not have been material. Because the disclosures specified in Rule 13-01(a) are only required to the extent material, we did not provide full summarized financial information in the First Quarter 10-Q¹. Instead, we provided qualitative disclosure regarding the nature of each Obligor Group and the relationships among the members within each Obligor Group, each of which is a holding company with subsidiary operating companies, and we provided certain quantitative balance sheet disclosures, including external debt and intercompany notes payable to and receivables from non-guarantor subsidiaries.

In response to the Staff’s comment, we have updated the disclosures in our Form 10-Q for the quarter ended June 30, 2020 to (i) expand the description of the “combined” basis of presentation for the quantitative information related to each Obligor Group; (ii) present the quantitative disclosures for Comcast Holdings, as subsidiary issuer, on a combined basis with Comcast, as guarantor; (iii) provide comparative balances for the notes payable to and receivables from non-guarantor subsidiaries as of December 31, 2019 and specify that the amounts disclosed are classified as non-current; and (iv) disclose that excluding investments in non-guarantor subsidiaries, external debt and the non-current notes payable to and receivables from non-guarantor subsidiaries, the entities in each Obligor Group do not have material assets, liabilities or results of operations.