UNITEDSTATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON D.C 20549-3010 DIVISION OF CORPORATION FINANCE December 19 2007 Andrew Bor Perkins Coie 1201 Third Avenue Suite 4800 Seattle WA 98101-3099 Re Fisher Communications Inc Incoming letter dated November 29 2007 Dear Mr Bor This is in response to your letters dated November 29 2007 and December 11 2007 concerning the shareholder proposal submitted to Fisher Communications by GAMCO Asset Management Inc We also have received letter from the proponent dated December 2007 Our response is attached to the enclosed photocopy of your correspondence By doing this we avoid having to recite or summarize the facts set forth in the correspondence Copies of all of the correspondence also will be provided to the proponent In connection with this matter your attention is directed to the enclosure which sets forth brief discussion of the Divisions informal procedures regarding shareholder proposals Sincerely Jonathan Ingram Deputy Chief Counsel Enclosures cc Peter Goldstein Director of Regulatory Affairs GAMCO Asset Management Inc One Corporate Center Rye NY 10580-1435-1422 December 19 2007 Response of the Office of Chief Counsel Division of Corporation Finance Re Fisher Communications Inc Incoming letter dated November 29 2007 The proposal relates to acquisitions for view that Fisher Communications There appears to be some basis your may Fisher Communications received it exclude the proposal under rule 14a-8e2 because after the deadline for submitting proposals We note in particular your representations able and that an individual at Fisher Communications principal executive offices was 2007 and that authorizedto receive accept and sign for packages on November 23 will recommend delivery was not attempted on that date Accordingly we not enforcement action to the Commission if Fisher Communications omits the proposal in reliance rule from its proxy materials on 14a-8e2 Sincerely John Fieldsend Attorney-Advisor Perkins 1\ECELEIJ Goie Uffl DEC PM 33 Andrew l3or 1201 Third Avenue Suite 4800 PHONE 206 359 8577 CCLN3 SeattleWA 98101-3099 iOn FIr4MTu FAX 206 359-9577 PHONE 206.359.8000 EMAIL [email protected] FAX 206.359.9000 November 29 2007 VIA OVERNIGHT COURIER U.S Securities and Exchange Commission Division of Corporation Finance Office of Chief Counsel 100 Street N.E Washington D.C 20549 Re Shareholder Proposal Submitted by GAMCO Asset Management Inc for Inclusion in the Fisher Communications Inc 2008 Proxy Statement Dear Sir or Madam We are counsel to Fisher Communications Inc Washington corporation the Company and On November 26 2007 the Company received shareholder proposal supporting statement together the Proposal from GAMCO Asset Management Inc the distributed to the Proponent for inclusion in the proxy statement to be Companys shareholders in connection with its 2008 Annual Meeting of Shareholders the 2008 Proxy Statement The purpose of this letter is to notify the Securities and Exchange Commission the Commission of the Companys intent to exclude the Proposal from the 2008 Proxy Statement The Proposal is being excluded from the 2008 Proxy Statement because it was not submitted within the time period specified by the Company in accordance with Commission Rule Rule 4a-8e under the Securities Exchange Act of 1934 as amended Rule 4a8e2 states that shareholder proposal must be received at the companys principal executive offices not less than 120 calendar days before the date of the companys with the annual proxy statement released to shareholders in connection previous years meeting for such submission to be deemed timely filed for Rule 14a-8 purposes Emphasis added Consistent with the requirements of Rule 14a-8e2 the November 24 2007 deadline referenced in the Companys proxy statement for its 2007 Annual Meeting of Shareholders the 2007 Proxy Statement is 120 calendar days before the date of the in connection with the Companys proxy statement released to shareholders previous years annual meeting The November 24 2007 deadline remains effective because the Company intends to hold the 2008 Annual Meeting of Shareholders not more than 30 days from the date of the previous years meeting 09648-0004/LEGAL13761461 .2 ANCHORAGE BEIJING BELLEVUE BOISE- CHICAGO -DENVER LOS ANGELES MENLO PARK OLYMPIA PHOENIX PORTLAND SAN FRANCISCO SEATTLE WASHINGTON DC Perkins Coie Lu and Affiliates Securities and Exchange Commission November 29 2007 Page The Proposal and the accompanying letter from Mr Peter Goldstein the Proponents received Director of Regulatory Affairs Mr Goldstein dated November 21 2007 were 2007 deadline by the Company on November 26 2007 two days after the November 24 Statement The calculated pursuant to Rule 14a-8e and disclosed in the 2007 Proxy number the Proponent sent the Proposal via DHL DHL tracking 65484251140 Entering that the item not delivered tracking number on the DHL website confirms conclusively was attached to this until November 26 2007 at 931 a.m copy of the delivery confirmation is letter as Exhibit of shareholder The Commission staff has strictly construed the deadline for receipt proposals omit from materials under Rule 4a-8e and has consistently permitted companies to proxy deadline without as to the reason for failure to those proposals received after the inquiring meet the deadline even in cases where the proposals were only one or two days late See Business Machines e.g Smithfield Foods Inc June 2007 International Corp Dec 2006 JPMorgan Chase Co Feb 2005 American Express Co Dec 21 2004 Hewlett-Packard Co Jan 24 2003 The burden is on the shareholder to ensure that the proposal is received by the company by the required deadline that the does not meet the For the reasons outlined above the Company believes Proposal be omitted from the 2008 timeliness requirements of Rule 14a-8e2 and may Proxy that it will Statement The Company respectfully requests that the Commission staff confirm if the is excluded from the 2008 not recommend any enforcement action Proposal Proxy Statement In accordance with Rule 14a-8j the Company hereby files six copies of this letter and the intends to file Proposal which is attached to this letter as Exhibit The Company presently to Rule its definitive proxy materials on or about March 21 2008 Accordingly pursuant calendar before the will l4a-8.j this letter is being submitted not less than 80 days Company with the Rule that file its definitive 2008 Proxy Statement Commission 14a-8f requires within 14 of company notify proposing shareholder of any deficiencies in the proposal days be receipt However this requirement does not apply to deficiency that cannot remedied determined such as when the proponent fails to submit proposal by the companys properly deadline via Also in accordance with Rule 14a-8j the Company is simultaneously forwarding notice to the overnight courier copy of this letter and its attachments to Mr Goldstein as from the 2008 Proponent of the Companys intention to exclude the Proposal Proxy Statement the enclosed of Please acknowledge receipt of this letter and its enclosures by stamping copy in the enclosed In the event that the Commission this letter and returning it to me envelope of the would the staff disagrees with the Companys course action Company appreciate 09648-0004/LEGAL 13761461.2 Securities and Exchange Commission November 29 2007 Page to this letter Please do not opportunity to confer with the staff before it issues response hesitate to call me at 206 359-8577 Very truly yours An rew Bor Enclosures cc Peter Goldstein GAMCO Asset Management Inc Inc Mae Fujita Numata Fisher Communications 09648-0004/LEGAL13761461 .2 EXHIBIT 09648-0004/LEGAL 3761461.2 of DHL Print Delivery Signature detail Page Print this Delivery Signature Detail page Signature details for 65484251140 RcEIVEB IN GOOD ORSER EXCEPT ASNOlED Summarydetails Current Status Shipment Delivered Delivered on 11/26/07 931 am Delivered to Receptionist Signed for by HUGHES Receiver Information Please retry later to obtain receiver infomation 12522 PM Tracking detail provided by DHL 11/28/2007 DHL other You are authorized to use DHL tracking systems solely to track shipments tendered by or for you to Any use of DHL tracking systems and information is strictly prohibited 11/28/2007 http//sigpod.dhl-usa.comlprintbysig.asp EXHIBIT 09648-0004/LEGAL 1376 1461.2 lJtk One Corporate Center kk i1i_ /o Rye NY 10580-1435-1422 TeL 914 921-7732 pgaIdstongabellicom CFLOW GAMCO Asset Management Inc November 21 2007 Via Overnight Delivery Mae Fujita Numata Senior Financial Vice President Chief Officer and Corporate Secretary Fisher Communications Inc 100 4th Avenue North Suite 510 Seattle WA 98109 Re Shareholder Proposal Dear Ms Numata am enclosing on behalf of GAMCO Asset Management Inc GAMCO shareholder proposal and supporting statement Under Rule 14a-8 of the Securities Exchange Act of 1934 am requesting that Fisher Communications Inc Fisher include the proposal in its proxy statement for the 2008 annual meeting GAMCO is proposing that shareholders be asked to vote on resolution that the By-Laws of Fisher be amended to provide that any decision by Fisher to engage in transaction either through acquisition of assets stock or otherwise by which Fisher would acquire an operating business and for which the consideration paid by Fisher would exceed $25 million requires majority vote of the shareholders and that the amended by-law thereafter may only be amended or repealed by majority vote of Fishers shareholders Currently GAMCO beneficially owns approximately 1029449