United States securities and exchange commission logo January 20, 2023 Wallace Cooney Chief Financial Officer Graham Holdings Co 1300 North 17th Street Arlington, VA 22209 Re: Graham Holdings Co Form 10-K for Fiscal Year Ended December 31, 2021 Filed February 25, 2022 File No. 001-06714 Dear Wallace Cooney: We have completed our review of your filings. 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