FOXAFox Corporation (Class A)

We note that you made reference to, and defined, Total Segment EBITDA, a non-GAAP measure, within the context of ASC 280 disclosures. Please note, non-GAAP financial measures should not be presented in the financial statements. Please remove that characterization. Refer to guidance in Item 10(e)(1)(ii)(C) of Regulation S-K.

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In addition, the current caption “Total Segment EBITDA” is the same as, or confusingly similar to, Segment EBITDA, which is a GAAP financial measure for segment performance pursuant to ASC 280. It is also confusingly similar to EBITDA, but contains adjustments for items other than interest, taxes, depreciation and amortization. If you present a similar measure in future filings, please ensure that measures calculated differently from EBITDA are not characterized as EBITDA. Refer to Question 103.01 of the Compliance and Disclosure Interpretations Non-GAAP Financial Measures updated April 4, 2018. Furthermore, please provide a reconciliation of the subject non-GAAP measure to net income, its most comparable GAAP measure. All required non-GAAP disclosures should be provided outside the segment footnote and apart from your segment analysis on page 35. Refer to Items 10(e)(1)(i) of Regulation S-K and Question 103.02 of the Compliance and Disclosure Interpretations Non-GAAP Financial Measures updated April 4, 2018. Please provide us with your proposed disclosure which you will include in future filings. 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.

to the Staff’s comments, the Company will revise (1) its segment disclosure in the notes to the financial statements in future filings to exclude the non-GAAP financial measure “Total Segment EBITDA” and (2) its segment analysis disclosure in Management’s Discussion and Analysis of Financial

Condition and Results of Operations by moving the non-GAAP disclosure to a “Non-GAAP Financial Measures” section after the segment analysis.

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In addition, the

Company will rename the non-GAAP financial measure “Total Segment EBITDA” as “Adjusted EBITDA” and provide a reconciliation of Net income to Adjusted EBITDA. The illustrative revised disclosures are set forth in Appendix A and Appendix B to this letter. The revised disclosures will be presented in the next quarterly report on Form 10-Q.

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