February 25, 2025

Timothy Millage
Chief Financial Officer
Lee Enterprises, Incorporated
4600 East 53rd Street
Davenport, IA 52807

       Re: Lee Enterprises, Incorporated
           Form 10-K for the Fiscal Year Ended September 29, 2024
           Form 8-K furnished February 7, 2025
           File No. 001-06227
Dear Timothy Millage:

       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 September 29, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources, page 24

1.     Please provide a more informative analysis and discussion of changes in
operating,
       investing and financing cash flows for each period presented. In doing
so, explain the
       underlying reasons and implications of material changes between periods
to provide
       investors with an understanding of trends and variability in cash flows.
Also provide
       an analysis of any known trends and uncertainties that will result in or
that are
       reasonably likely to result in a material increase or decrease in your
liquidity. Ensure
       your discussion and analysis is not merely a recitation of changes
evident from the
       financial statements. Refer to Item 303(a) of Regulation S-K and Section
IV.B of SEC
       Release No. 33-8350.
4. Goodwill and Other Intangible Assets, page 45

2.     Please tell us in sufficient detail how you determined, pursuant to ASC
350-20-35-33
 February 25, 2025
Page 2

       through -38, that your business consists of a single reporting unit.
Explain if there are
       any components of your reporting unit and, if so, how they qualify for
aggregation. As
       part of your response, clarify if your business still consists of
strategic business
       units as discussed in a prior comment response letter dated February 10,
2022.
Form 8-K furnished on February 7, 2025
Exhibit 99.1 Earnings Release, page 1

3.     We note that you disclose the percentage change in several revenue
streams on page 1
       without explicitly identifying them as non-GAAP "same-store" figures.
Please
       appropriately title each non-GAAP figure and ensure you present the
change in GAAP
       revenue with equal or greater prominence. See Item 10(e)(1)(i)(A) of
Regulation S-K
       and Question 102.10(a) of the Compliance and Disclosure Interpretations
on Non-
       GAAP Financial Measures.
Exhibit 99.2 Presentation Materials, page 7

4.     We note your presentation of "digital gross margin" percentage. In
future filings,
       please present gross profit for each revenue stream and on a
consolidated basis. Since
       you do not present gross profit on the face of your consolidated
statements of (loss)
       income, disclose the nature of the expenses included within cost of
sales and ensure
       that it is inclusive of all necessary expenses.
5.     We note that you disclose on page 12 a 2025 fiscal year outlook for
Adjusted
       EBITDA without providing a reconciliation to the most directly related
GAAP
       measure. In future filings, please include such reconciliation or,
alternatively, provide
       a statement that the information could not be presented without
unreasonable efforts
       under Item 10(e)(1)(i)(B) of Regulation S-K. Refer also to Questions
102.10(a) and
       102.10(b) of the C&DI's on Non-GAAP Financial Measures. Additionally,
       considering you present Adjusted EBITDA on a consolidated basis, tell us
your basis
       for only providing an outlook for digital revenue and not consolidated
revenues.
        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 Melissa Gilmore at 202-551-3777 or Andrew Blume at
202-551-3254
with any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Manufacturing