United States securities and exchange commission logo
October 13, 2020
Wallace Cooney
Chief Financial Officer
Graham Holdings Company
1300 North 17th Street
Arlington, VA 22209
Re: Graham Holdings
Company
Form 10-K for the
Fiscal Year Ended December 31, 2019
Filed February 26,
2020
File No. 1-6714
Dear Mr. Cooney:
We have completed our review of your filing. 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.
Sincerely,
Division of Corporation Finance
Office of Trade & Services