February 14, 2019

Timothy R. Millage
Chief Financial Officer
Lee Enterprises, Incorporated
201 N. Harrison Street, Suite 600
Davenport, Iowa 52801

       Re: Lee Enterprises, Incorporated
           Form 10-K for the Fiscal Year Ended September 30, 2018
           Form 8-K furnished February 8, 2019
           File No. 001-06227

Dear Mr. Millage:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended September 30, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Continuing Operations, page 25

1.    We note that you present your results of operations on a "same property
basis." We
      further note that in doing so, you have not quantified the impact of each
of the items on
      page 25 in your results of operations analysis. As an example, you state
that advertising
      and marketing services revenue decreased by 8.4% in 2018 and by 11.4% on
a same
      property basis. However, the impacts of revenues from 2017 acquisitions,
revenues from
      disposed enterprises in 2018, and the 53rd week of revenue in 2018 are
not quantified to
      enable a reader to better understand how each item impacted the line
items in your
      statement of operations. Please provide a more robust operating results
      discussion, including the quantifications of various factors behind the
changes in revenues
      and expenses, to the extent that they are material, in understanding your
operations. Refer
      to Item 303 of Regulation S-K.
 Timothy R. Millage
Lee Enterprises, Incorporated
February 14, 2019
Page 2
Financial Statements
Notes to Consolidated Financial Statements
1. Significant Accounting Policies
Inventories, page 45

2.       We note that you recognize inventory at the lower of cost or market.
As it relates to your
         inventory measured using FIFO, please explain how this complies with
the policy of using
         the lower of cost or net realizable value in accordance with ASC
330-10-35-1B.
Form 8-K furnished February 8, 2019

Exhibit 99.1 Earnings Release
Consolidated Statements of Operations, page 5

3.       We note that in your consolidated statements of operations disclosed
on page 5, you have
         included the subtotal "total operating revenue less cash costs." This
measure appears to be
         a non-GAAP financial performance measure and your disclosure should be
revised to
         include the disclosures required under Regulation G and Item
10(e)(1)(i) of Regulation S-
         K. As part of these disclosures you should reconcile the measure to
the most directly
         comparable GAAP measure and explain why you believe the measure is
useful to
         investors.
       In closing, 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.

       You may contact Heather Clark at 202-551-3624 or Claire Erlanger at
202-551-3301 with
any questions.



FirstName LastNameTimothy R. Millage                          Sincerely,
Comapany NameLee Enterprises, Incorporated
                                                              Division of
Corporation Finance
February 14, 2019 Page 2                                      Office of
Transportation and Leisure
FirstName LastName