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                            April 1, 2024

       David T. Lougee
       Chief Executive Officer
       TEGNA INC
       8350 Broad Street
       Suite 2000
       Tysons, Virginia 22102-5151

                                                        Re: TEGNA INC
                                                            Form 10-K for the 
fiscal year ended December 31, 2023
                                                            Filed on February 
29, 2024
                                                            Form 8-K
                                                            Filed on February 
29, 2024
                                                            File No. 001-06961

       Dear David T. Lougee:

              We have limited our review of your filing to the financial 
statements and related
       disclosures and have the following comments.

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

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

       Form 10-K for the fiscal year ended December 31, 2023

       Management's Discussion and Analysis of Financial Condition and Results 
of Operations
       Operating results non-GAAP information, page 38

   1.                                                   We note the tabular 
disclosure on page 38 showing non-GAAP reconciliations of certain
                                                        line items to the most 
directly comparable financial measures calculated and presented in
                                                        accordance with GAAP. 
Please revise your presentation as this appears to be a non-GAAP
                                                        income statement. We 
refer you to Question 102.10(c) in the Compliance and Disclosure
                                                        Interpretations on 
Non-GAAP Financial Measures.
       Free cash flow reconciliation, page 40

   2.                                                   You disclose free cash 
flow is a non-GAAP performance measure that the Board of
 David T. Lougee
TEGNA INC
April 1, 2024
Page 2
         Directors uses to review the performance of the business. Tell us how 
you determined that
         the label used for this non-GAAP measure reflects its nature and help 
us better understand
         why you appear to be making cash-based adjustments to a non-GAAP 
measures that is
         reconciled to GAAP net income/(loss). Also, explain your basis for 
presenting free cash
         flow for a two-year period. We refer you to Item 10(e)(1)(i) of 
Regulation S-K,
         Regulation G, and Questions 100.05 and 102.07 in the Compliance and 
Disclosure
         Interpretations on Non-GAAP Financial Measures. In addition, this 
comment also applies
         to the free cash flow non-GAAP measure presented in your Form 8-K 
filed on February
         29, 2024.

Form 8-K filed on February 29, 2024

Use of Non-GAAP Information, page 10

3.       We note your disclosure of the non-GAAP measure Operating expenses, 
less
         Programming. Please describe the nature of programming expenses and 
tell us how you
         considered whether these costs are a normal, recurring operating 
expense for which a non-
         GAAP adjustment is inconsistent with Question 100.01 in the Compliance 
and Disclosure
         Interpretations on Non-GAAP Financial Measures.

       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.

      Please contact Morgan Youngwood at 202-551-3479 or Stephen Krikorian at 
202-551-
3488 with any questions.



FirstName LastNameDavid T. Lougee                             Sincerely,
Comapany NameTEGNA INC
                                                              Division of 
Corporation Finance
April 1, 2024 Page 2                                          Office of 
Technology
FirstName LastName