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                              August 1, 2022

       Frank Lopez-Balboa
       Executive Vice President, Chief Financial Officer
       Cumulus Media Inc.
       780 Johnson Ferry Road NE Suite 500
       Atlanta, GA 30342

                                                        Re: Cumulus Media Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Form 10-Q for the
Fiscal Quarter Ended March 31, 2022
                                                            Form 8-K filed May
4, 2022

       Dear Mr. Lopez-Balboa:

              We have reviewed your filings 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-Q for the Fiscal Quarter Ended March 31, 2022

       Item 2. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Consolidated Results of Operations, page 16

   1.                                                   We note that revenue
increased by 15% for the three months ended March 31, 2022
                                                        compared with the three
months ended March 31, 2021. Please enhance your disclosure
                                                        to quantify the reasons
for the increase in revenue. For example, disclose how much of
                                                        the increase is a
result of a one time fee received from the early termination of a revenue
                                                        agreement. We refer to
guidance in Item 303 of Regulation S-K. Provide us with your
                                                        proposed future
disclosure.
 Frank Lopez-Balboa
Cumulus Media Inc.
August 1, 2022
Page 2
Form 8-K filed May 4, 2022

Exhibit 99.2, page 3

2.    Please revise your presentation to disclose and emphasize the most
comparable GAAP
      measures for EBITDA, EBITDA growth, EBITDA Margin, and net debt with
equal or
      greater prominence. Refer to the guidance in Item 10(e)(1)(i)(A) of
Regulation S-K and
      Question 102.10 of the Compliance and Disclosure Interpretations on
Non-GAAP
      Measures. We note GAAP results should be at the forefront of your
presentation and
      discussion. Also, include a reconciliation for EBITDA and EBITDA Margin
in
      accordance with Item 10(e)(1)(i)(B) of Regulation S-K . Apply accordingly
to your
      Exhibit 99.1.
        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 Inessa Kessman, Senior Staff Accountant at 202-551-3371
or Robert
Littlepage, Accounting Branch Chief at 202-551-3361 if you have any questions.



                                                          Sincerely,
FirstName LastNameFrank Lopez-Balboa
                                                          Division of
Corporation Finance
Comapany NameCumulus Media Inc.
                                                          Office of Technology
August 1, 2022 Page 2
cc:       Richard Denning
FirstName LastName