SEC comment letters for SEC reporting preparers

Company response: We respectfully submit below the response of Lionsgate Studios Corp., a British Columbia, Canada corporation (“Lionsgate,” the “Company,” “we,” “us,” or “our”), to the comment from the United States Securities and Exchange Commission staff (the “Staff”) regarding our Annual Report on Form 10-K for fiscal year ended March 31, 2026 contained in your letter dated July 21, 2026. For your convenience, we have included your original comments below in italics, immediately followed by our response. Form 10-K for Fiscal Year Ended March 31, 2026 Management's Discussion and Analysis of Financial Condition and Results of Operations Segment Results of Operations and Non-GAAP Measures, page 52 Comment 1… response letter →

Company response: The Company acknowledges the Staff’s Comment and respectfully advises the Staff that the Company tracks external research and development expenses on a clinical trial-specific basis while aggregating such expenses for its preclinical studies. The Company undertakes to provide disclosure substantially in the form presented below in its future filings with the Commission. Research and development expenses consist primarily of costs incurred for the discovery and development of our product candidates. Given the number of programs that we have and, because some of our clinical trials may combine more than one program, we track the external research and development costs incurred per clinical… response letter →

Company response: The Company respectfully advises the Staff that, upon inception of the 2023 Gilead License Agreement, it identified three performance obligations. The agreement also provided Gilead with an option to purchase drug supply of GS-0321. The Company concluded that this option did not provide a material right and therefore did not represent a separate performance obligation. During the first half of 2026, Gilead exercised its option to purchase additional goods and services related to the supply of GS-0321. The Company undertakes to update its disclosure in future filings with the Commission to reflect the exercise of this option. The Company further advises the Staff that revenue associated with… response letter →

Company response: The Company acknowledges the Staff’s comment and confirms that in the future it will revise the footnote to the Schedule of Investments in its Quarterly Reports on Form 10-Q and its next Annual Report on Form 10-K to reflect that the value of Level 3 holdings was determined using significant unobservable inputs as required by Article 12-12, footnote 9 of Regulation S-X consistent with the following: Unless otherwise noted, security is a Level 3 holding. As of December 31, 2025, the aggregate value of Level 3 securities held by the Company was $2,151,743. The value of each investment was determined using unobservable inputs. See Note 5 – Fair Value. response letter →

Company response: The Company acknowledges the Staff’s comment and confirms that in the future it will include disclosure regarding non-recurring income in the MD&A or in the notes to its financial statements in its Quarterly Reports on Form 10-Q and its next Annual Report on Form 10-K consistent with the following: Revenue Recognition We do not accrue as a receivable interest on loans and debt securities for accounting purposes if we have reason to doubt our ability to collect such interest. OIDs, upfront loan origination fees, amendment fees, market discounts or premiums are accreted or amortized using the effective interest method as interest income. We record prepayment premiums on loans and debt… response letter →

Company response: As of March 31, 2026, the Company invested 4.6% of its net assets in unitranche loans, consisting of debt investments in three entities: Arborworks Acquisition, LLC; PMFC Holding, LLC; and Centerline Communications, LLC. response letter →

Company response: The Company acknowledges the Staff’s comment and confirms that in the future it will include incentive fee examples in its next Annual Report on Form 10-K consistent with the examples provided on pages 127-134 of its Registration Statement on Form N-2 (File No. 333-278414), filed by the Company with the Commission on May 13, 2024, and declared effective on May 21, 2024. * * * * response letter →

Company response: We hereby confirm that in future periodic filings, we will revise our officer certifications to include introductory language within paragraph 4 and the entirety of paragraph 4(b) pertaining to internal control over financial reporting. We appreciate the assistance the Staff has provided with its comments. response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and has revised its disclosure throughout the Proxy Statement and on the proxy card to make clear the separation of Proposal 3 into individual proposals 3A through 3H. The Company has also added additional disclosure regarding the conditionality of each proposal on the other proposals included in the Proxy Statement. * * * * * response letter →

Company response: The Company evaluated the accounting for the 2024 convertible senior note repurchases in accordance with ASC 470-20-40-13 through 40-17, which addresses the accounting for changes made by the debtor to the conversion privileges for the purpose of inducing conversion. AUSTIN | BOSTON | BRUSSELS | CHICAGO | DALLAS | DENVER | DETROIT | HOUSTON | JACKSONVILLE | LOS ANGELES MADISON | MEXICO CITY | MIAMI | MILWAUKEE | NASHVILLE | NEW YORK | ORLANDO | RALEIGH | SACRAMENTO | SALT LAKE CITY | SAN DIEGO | SAN FRANCISCO | SILICON VALLEY | TALLAHASSEE | TAMPA | TOKYO | WASHINGTON, D.C. 4912-7375-8879.1 U.S. Securities and Exchange Commission The Company determined that both criteria in paragraph… response letter →

Company response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that the Company has revised the disclosure beginning on page 1 of the Form 10-K/A and beginning on page 4 of the Public Filing Form S-3 to address the legal and operational risks associated with having the Company’s revenue generating business in Hong Kong. Additionally, the Company has revised the disclosure beginning on page 13 of the Form 10-K/A to include risk factors related to doing business in Hong Kong. Please note that the Form 10-K/A is incorporated by reference into the Public Filing Form S-3. U.S. Securities and Exchange Commission Division of Corporation Finance Office of Technology If you should… response letter →