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                              February 18, 2022

       Marshall Anstandig
       Senior Vice President and General Counsel
       MNG Enterprises, Inc.
       5990 Washington Street
       Denver, CO 80216

                                                        Re: LEE ENTERPRISES,
Inc
                                                            PRRN14A filed
February 16, 2022
                                                            Filed by MNG
Enterprises, Inc. et al.
                                                            SEC File No.
1-06227

       Dear Mr. Anstandig:

              We have reviewed your filing 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 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.

       Revised Preliminary Proxy Statement filed February 16, 2022

       Background to the Solicitation, page 5

   1.                                                   Briefly explain that
you initially attempted to nominate two director candidates, and later
                                                        converted your
solicitation into a "vote no" campaign against two of the Company's
                                                        nominees because the
Delaware court invalidated those nominations.
   2.                                                   Balance the disclosure
in the last paragraph on page 6 to state that even if the Company's
                                                        nominees fail to
receive a majority of the votes cast, it is not clear that they would not
                                                        continue to serve on
the Board, despite your view that this would be inappropriate.
       Votes Required for Approval - Election of Directors, page 11

   3.                                                   Describe the dispute
about the voting standard that applies to the election of directors
                                                        earlier in the proxy
statement, in a prominent location at the forepart of the disclosure
                                                        document. Your revised
disclosure should note that the Company asserts that a plurality
 Marshall Anstandig
MNG Enterprises, Inc.
February 18, 2022
Page 2
         voting standard applies, and the basis for your disagreement. Your
revised disclosure
         should note that any proxies granted to you may have no legal effect
unless the Company
         accepts that a majority voting standard applies. Finally, indicate
your intentions with
         regard to further action, whether through litigation or otherwise, if
the Company continues
         to maintain the position that a plurality voting standard applies.
Please be specific about
         what actions you may pursue and under what circumstances. For example,
if you
         will pursue a court challenge but only if you receive sufficient
proxies to prevent the
         Company nominees from being elected under a majority voting standard,
so state.
4.       See our last comment above. Revise generally to discuss what will
occur with proxies
         granted to you which include a voting option applicable to a majority
voting standard, if
         the Company refuses to concede that such standard applies to the
election of directors and
         no court challenge occurs, or if you are unsuccessful in such
challenge.
5.       Explain why you include an "AGAINST" (rather than a "WITHHOLD") voting
option on
         your proxy card, while the Company does not. That is, explain what
will be the effect of
         an "AGAINST" vote if a plurality voting standard applies.
Revocation of Proxies, page 12

6.       There appears to be a word missing from the last sentence at the
bottom of page 12.
         Please revise.
Form of Proxy - Election of Directors, page III-4

7.       Since there is only one Company nominee other than Ms. Junck and Mr.
Maloney, it
         appears that the third voting option duplicates the first voting
option. Please revise.
8.       It is not clear what option the Instructions refer to for the ability
to be able to vote
         "AGAINST" a particular nominee, since there is no option provided to
mark "AGAINST
         ALL EXCEPT" box. Please revise or clarify.
        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

         Please direct any questions to Christina Chalk at (202) 551-3263.



FirstName LastNameMarshall Anstandig                           Sincerely,
Comapany NameMNG Enterprises, Inc.
                                                               Division of
Corporation Finance
February 18, 2022 Page 2                                       Office of
Mergers & Acquisitions
FirstName LastName