[767 Fifth Avenue New York, NY 10153-0119 +1 212 310 8000 tel +1 212 310 8007 fax October7, 2013 VIA EDGAR TRANSMISSION Division ofrporation Finance 100 F Street NE Max A. Webb Re: AMC Entertainments,Inc. Amendment No.1 to Registration Statement on FormS-1 Dear Mr.Webb: For ease of reference, each of the Staffsmments is reproduced below]
[767 Fifth Avenue New York, NY 10153-0119 +1 212 310 8000 tel +1 212 310 8007 fax October7, 2013 VIA EDGAR TRANSMISSION Division ofrporation Finance 100 F Street NE Max A. Webb Re: AMC Entertainments,Inc. Amendment No.1 to Registration Statement on FormS-1 Dear Mr.Webb: For ease of reference, each of the Staffsmments is reproduced below]
[FORM S-1 REGISTRATION STATEMENT AMC ENTERTAINMENT HOLDINGS, INC. Delaware 7832 26-0303916 One AMC Way Kevin M. Connor, Esq. Copies of Communications to: Matthew D. Bloch, Esq. Approximate date of commencement of proposed sale to public: o o o o o Large accelerated filer o Accelerated filer ý Non-accelerated filer (Do not check if a o Smaller reporting company Title of] [AMC ENTERTAINMENT HOLDINGS, INC. AND SUBSIDIARIES (AND JURISDICTION OF ORGANIZATION) AMC Entertainment Inc. (Delaware) Movietickets.com, Inc. (Delaware) (26.2%) LCE AcquisitionSub, Inc. (Delaware) LCE Mexican Holdings, Inc. (Delaware) American Multi-Cinema, Inc. (Missouri) AMC Card Processing Services, Inc. (Arizona) AMC License Services, Inc. (Kansas) AMC ITD, Inc. (Kansas) AMC Theatres of New Jersey, Inc. (Delaware) Loews Kaplan Cinema Associates Partnership (50%) Centertainment] [Consent of Independent Registered Public Accounting Firm The Board of Directors and Stockholders We consent to the use of our report dated August 27, 2013 with respect to the consolidated balance sheets of AMC Entertainment Holdings, Inc. as of December 31, 2012 and March 29, 2012, and the related consolidated statements of operations, comprehensive earnings (loss), stockholders equity, and cash] [CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the use in this Registration Statement on Form S-1 of AMC Entertainment Holdings, Inc. of our report dated March 20, 2013 related to the financial statements of National CineMedia, LLC appearing in the Prospectus, which is part of this Registration Statement. We also consent to the reference to us under] [Consent of Independent Auditors We consent to the inclusion in this registration statement on Form S-1 of AMC Entertainment Holdings, Inc. of our report dated February 20, 2013, on our audits of the consolidated financial statements of Digital Cinema Implementation Partners, LLC and Subsidiaries as of December 31, 2012 and 2011 and for each of the years in the three-year] [Consent of Independent Registered Public Accounting Firm We consent to the use of our report dated February 6, 2013, with respect to the consolidated balance sheets of Open Road Releasing, LLC as of December 31, 2012 and 2011, and the related consolidated statements of operations, changes in members equity, and cash flows for each of the years in the two-year]
[FORM S-1 REGISTRATION STATEMENT AMC ENTERTAINMENT HOLDINGS, INC. Delaware 7832 26-0303916 One AMC Way Kevin M. Connor, Esq. Copies of Communications to: Matthew D. Bloch, Esq. Approximate date of commencement of proposed sale to public: o o o o o Large accelerated filer o Accelerated filer ý Non-accelerated filer (Do not check if a o Smaller reporting company Title of] [AMC ENTERTAINMENT HOLDINGS, INC. AND SUBSIDIARIES (AND JURISDICTION OF ORGANIZATION) AMC Entertainment Inc. (Delaware) Movietickets.com, Inc. (Delaware) (26.2%) LCE AcquisitionSub, Inc. (Delaware) LCE Mexican Holdings, Inc. (Delaware) American Multi-Cinema, Inc. (Missouri) AMC Card Processing Services, Inc. (Arizona) AMC License Services, Inc. (Kansas) AMC ITD, Inc. (Kansas) AMC Theatres of New Jersey, Inc. (Delaware) Loews Kaplan Cinema Associates Partnership (50%) Centertainment] [Consent of Independent Registered Public Accounting Firm The Board of Directors and Stockholders We consent to the use of our report dated August 27, 2013 with respect to the consolidated balance sheets of AMC Entertainment Holdings, Inc. as of December 31, 2012 and March 29, 2012, and the related consolidated statements of operations, comprehensive earnings (loss), stockholders equity, and cash] [CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the use in this Registration Statement on Form S-1 of AMC Entertainment Holdings, Inc. of our report dated March 20, 2013 related to the financial statements of National CineMedia, LLC appearing in the Prospectus, which is part of this Registration Statement. We also consent to the reference to us under] [Consent of Independent Auditors We consent to the inclusion in this registration statement on Form S-1 of AMC Entertainment Holdings, Inc. of our report dated February 20, 2013, on our audits of the consolidated financial statements of Digital Cinema Implementation Partners, LLC and Subsidiaries as of December 31, 2012 and 2011 and for each of the years in the three-year] [Consent of Independent Registered Public Accounting Firm We consent to the use of our report dated February 6, 2013, with respect to the consolidated balance sheets of Open Road Releasing, LLC as of December 31, 2012 and 2011, and the related consolidated statements of operations, changes in members equity, and cash flows for each of the years in the two-year]
[FORM S-1 REGISTRATION STATEMENT AMC ENTERTAINMENTS,INC. Delaware 7832 26-0303916 One AMC Way Kevin M.nnor, Esq.pies ofmmunications to: Matthew D. Bloch, Esq. Approximatete ofmmencement of proposedle to public: o o o o o Large accelerated filer o Accelerated filer Non-accelerated filer (Do not check if a] [AMC ENTERTAINMENTS,INC. AND SUBSIDIARIES (AND JURISDICTION OF ORGANIZATION) AMC Entertainment (Delaware) Movietickets.com,Inc. (Delaware) (26.2%) LCE AcquisitionSub,Inc. (Delaware) LCE Mexicans,Inc. (Delaware) American Multi-Cinema,Inc. (Missouri) AMCrd Processing Services,Inc. (Arizona) AMC License Services,Inc. (Kansas) AMC ITD,Inc. (Kansas) AMC Theatres of New Jersey,Inc. (Delaware) Loews Kaplan Cinemasociates Partnership (50%) Centertainment Development,Inc. (Delaware)] [Consent of Independent Registered Public Accounting Firm The Board of Directors and Stockholders Wensent to the use of our reportted August27, 2013 with respect to thensolidated balance sheets of AMC Entertainments,Inc. of December31, 2012 and March29, 2012, and the relatednsolidated statements of operations,mprehensive earnings (loss), stockholders equity, andsh flows for the August31, 2012 to December31,] [CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Wensent to the use in this Registration Statement on FormS-1 of AMC Entertainments,Inc. of our reportted March20, 2013 related to the financial statements of National CineMedia,LLC appearing in the Prospectus, which is part of this Registration Statement. Wesonsent to the reference to us under the heading Experts in] [Consent of Independent Auditors Wensent to thelusion in this registration statement on FormS-1 of AMC Entertainments,Inc. of our reportted February20, 2013, on our audits of thensolidated financial statements of Digital Cinema Implementation Partners, and Subsidiaries of December31, 2012 and 2011 and for each of the years in the three-year period ended December31, 2012. Wesonsent to] [Consent of Independent Registered Public Accounting Firm Wensent to the use of our reportted February6, 2013, with respect to thensolidated balance sheets of Open Road Releasing, of December31, 2012 and 2011, and the relatednsolidated statements of operations, changes in members equity, andsh flows for each of the years in the two-year period ended December31, 2012,]
[FORM S-1 REGISTRATION STATEMENT AMC ENTERTAINMENTS,INC. Delaware 7832 26-0303916 One AMC Way Kevin M.nnor, Esq.pies ofmmunications to: Matthew D. Bloch, Esq. Approximatete ofmmencement of proposedle to public: o o o o o Large accelerated filer o Accelerated filer Non-accelerated filer (Do not check if a] [AMC ENTERTAINMENTS,INC. AND SUBSIDIARIES (AND JURISDICTION OF ORGANIZATION) AMC Entertainment (Delaware) Movietickets.com,Inc. (Delaware) (26.2%) LCE AcquisitionSub,Inc. (Delaware) LCE Mexicans,Inc. (Delaware) American Multi-Cinema,Inc. (Missouri) AMCrd Processing Services,Inc. (Arizona) AMC License Services,Inc. (Kansas) AMC ITD,Inc. (Kansas) AMC Theatres of New Jersey,Inc. (Delaware) Loews Kaplan Cinemasociates Partnership (50%) Centertainment Development,Inc. (Delaware)] [Consent of Independent Registered Public Accounting Firm The Board of Directors and Stockholders Wensent to the use of our reportted August27, 2013 with respect to thensolidated balance sheets of AMC Entertainments,Inc. of December31, 2012 and March29, 2012, and the relatednsolidated statements of operations,mprehensive earnings (loss), stockholders equity, andsh flows for the August31, 2012 to December31,] [CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Wensent to the use in this Registration Statement on FormS-1 of AMC Entertainments,Inc. of our reportted March20, 2013 related to the financial statements of National CineMedia,LLC appearing in the Prospectus, which is part of this Registration Statement. Wesonsent to the reference to us under the heading Experts in] [Consent of Independent Auditors Wensent to thelusion in this registration statement on FormS-1 of AMC Entertainments,Inc. of our reportted February20, 2013, on our audits of thensolidated financial statements of Digital Cinema Implementation Partners, and Subsidiaries of December31, 2012 and 2011 and for each of the years in the three-year period ended December31, 2012. Wesonsent to] [Consent of Independent Registered Public Accounting Firm Wensent to the use of our reportted February6, 2013, with respect to thensolidated balance sheets of Open Road Releasing, of December31, 2012 and 2011, and the relatednsolidated statements of operations, changes in members equity, andsh flows for each of the years in the two-year period ended December31, 2012,]
