June 25, 2019

Mark Carleton
Chief Financial Officer
Qurate Retail, Inc.
12300 Liberty Boulevard
Englewood, Colorado 80112

       Re: Qurate Retail, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed February 28, 2019
           File No. 001-33982

Dear Mr. Carleton:

       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 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 December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations - Consolidated, page II-9

1.    Regarding your presentation of Consolidated Adjusted OIBDA. Please tell
us your
      consideration of Question 104.04 of the Compliance and Disclosure
Interpretations on
      Non-GAAP Financial Measures. In addition, we note your disclosure on page
II-10 that
      OIBDA is an important indicator of the operational strength and
performance of your
      businesses including each business's ability to service debt and fund
capital expenditures.
      Therefore, it appears that you use the measure as a liquidity measure.
Please tell us your
      consideration of Item 10(e)(1)(ii)(A) of Regulation S-K. Please note that
this comment
      also applies to your Form 10-Q for the quarter ended March 31, 2019.
 Mark Carleton
Qurate Retail, Inc.
June 25, 2019
Page 2
Consolidated Financial Statements
Notes to Consolidated Financial Statements
(2) Summary of Significant Accounting Policies
Revenue Recognition, page II-43

2.       Please explain to us why the total reduction in sales due to returns
for each of the years
         disclosed in the first full paragraph on page II-46 differ from the
amount of deductions in
         the table of the activity in the allowance for sales returns. Please
include in your
         response the items and amounts accounting for the differences.
(5) Disposals, page II-52

3.       Please tell us the nature of the payment "GCI Liberty Spilt-Off" in
the amount of $475
         million and revise your disclosure in future filings to disclose this
cash transaction in your
         discussion of the split-off. Further, please briefly describe or
provide a reconciliation of
         the components of the adjustment to equity for the GCI Liberty
Split-Off in the amount of
         $4,347 million.
        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 Donna Di Silvio, Staff Accountant at 202-551-3202 or Bill
Thompson,
Accounting Branch Chief at 202-551-3344 if you have any questions.



FirstName LastNameMark Carleton                                 Sincerely,
Comapany NameQurate Retail, Inc.
                                                                Division of
Corporation Finance
June 25, 2019 Page 2                                            Office of
Consumer Products
FirstName LastName