September 19, 2024

Wallace R. Cooney
Chief Financial Officer
Graham Holdings Company
1300 North 17th Street
Arlington, VA 22209

       Re: Graham Holdings Company
           Form 10-K for the Year Ended December 31, 2023
           File No. 001-06714
Dear Wallace R. Cooney:

       We have reviewed your filing and have the following comment.

       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 the
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 Year Ended December 31, 2023
Item 11. Executive Compensation, page 46

1.     From the disclosure incorporated by reference from page 18 of the
Definitive Proxy
       Statement filed on March 26, 2024, it appears that you have not provided
your disclosure
       about your recovery analysis in an Interactive Data File in accordance
with Rule 405 of
       Regulation S-T and the EDGAR Filer Manual. In future filings where you
conduct a
       recovery analysis, please also include the interactive data.
        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.
 September 19, 2024
Page 2

      Please contact Robert Arzonetti at 202-551-8819 or Sebastian Gomez Abero
at 202-551-
3578 with any other questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Finance