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[email protected] November 6, 2014 Securities Act of 1933 Section 4(a)(3) and Rule 174(b) Forms S-3, S-4 and S-8 Rule 414 Securities Exchange Act of 1934 Section 12(b) Rules 12g-3(c) and 12b-2 Office of the Chief Counsel Securities and Exchange Commission Division of Corporation Finance 100 F Street, N .E. Washington, D.C. 20549 Re: Media General, Inc.- Holding Company Reorganization Dear Sir or Madam, We are writing on behalf of Media General, Inc., a Virginia corporation ("Media General"), and Mercury New Holdco, Inc., a Virginia corporation ("New Media General"), to request the advice ofthe staffofthe Office ofthe ChiefCounsel, Division ofCorporation Finance (the "Staff') ofthe Securities and Exchange Commission (the "Commission") with respect to a number of succession-related issues under the Securities Act of 1933, as amended (the "Securities Act"), and the Securities Exchange Act of 1934, as amended (the "Exchange Act"). The issues arise out ofthe proposed acquisition by Media General, a NYSE-listed publicly traded company, of LIN Media LLC, a Delaware limited liability company ("LIN"), also a NYSE-listed publicly traded company. The acquisition will be effected through a two-step process. First, Media General will cause New Media General to become a new holding company of Media General by means of a merger of a subsidiary ofNew Media General with and into Media General (the "Holding Company Merger") under Section 13.1-719.1 ofthe Virginia Stock Corporation Act (which, like Section 251 (g) of the Delaware General Corporation Law, authorizes the formation of a holding company without a shareholder vote).