SecProbe.io

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						February 8, 2006

Mail Stop 3561

Via US Mail and Facsimile

Mr. Carl G. Schmidt
Vice President, Chief Financial Officer and Treasurer
201 N. Harrison Street, Suite 600
Davenport, Iowa 52801

Re:	Lee Enterprises, Incorporated
	Form 10-K for the year ended September 30, 2005
	Commission file #: 001-06227

Dear Mr. Schmidt:

We have reviewed your January 30, 2006 response letter and have
the
following comments.  Where expanded or revised disclosure is
requested, you may comply with these comments in future filings.
If
you disagree, we will consider your explanation as to why our
comments are inapplicable or a revision is unnecessary.  We also
ask
you to provide us with supplemental information so we may better
understand your disclosure.  Please be as detailed as necessary in
your explanation.  We look forward to working with you in these
respects and welcome any questions you may have about any aspects
of
our review.
* * * * * * * * * * * * * * * * * * * * * * *

Form 10-K for the year ended September 30, 2005

Management`s Discussion and Analysis

 - Overall Results, pages 19 and 22

1. We note from your response to our prior comment 4 that the
$1,200,000 amount related to settlement of Wisconsin income tax
audit
issues at less than the amount accrued for such issues.  Please
provide us with your accounting policy for accruing for pending
income tax audit issues including how you determine the amount to
be
accrued.  Also, please tell us the nature and amount of any other
pending audit issues for which an amount has been reserved and
explain why you believe recognition of these reserves is
appropriate
and in accordance with SFAS No.5.

Financial Statements

Consolidated Statements of Income and Comprehensive Income

2. We note from your response that you consider the operations of
your unconsolidated subsidiaries to be integral to your
operations.
Based on your response, we do not object to your inclusion of the
equity in your unconsolidated subsidiaries as part of operating
income.  We do however request that in future filings you present
only one line item on the face of the income statement for equity
in
earnings of associated companies and eliminate the subtotal
"operating income, before equity in earnings of associated
companies."  The detailed earnings related to each company should
be
included in the notes to the financial statements however.

Note 2. Acquisitions

- Acquisition of Pulitzer, page 44

3. We note from your response to our prior comment 10 that the
factors used to estimate the useful life of the advertiser lists
include attrition rates of existing advertisers, expected future
revenue growth from existing advertisers, and operating margins
generated by such advertisers.  Please provide us with detail of
the
historical retention/attrition experience of Pulitzers`
advertisers
including an explanation of how this historical experience
supports a
21 year useful life for customers acquired in the Pulitzer
acquisition.  Additionally, please give us details of the analysis
performed, including amounts, to show how the factors listed in
your
prior response were used to arrive at a 21 year useful life.

Note 4. Investments in Associated Companies

4. We note from your response to our prior comment 11 that the
carrying value of the CityXpress notes was $1,129,000 and that you
determined the fair value of the stock issued approximated the
carrying value of the notes at the time of conversion.  Please
tell
us and revise your note in future filings to disclose the
conversion
price that was used to convert the notes into common stock and the
number of common shares received.

Report on Form 8-K/A dated June 3, 2005 (filed June 20, 2005)

5. We note from your response to our prior comment 13 that you do
not
believe further discussion of the estimates related to the
intangibles is necessary in the pro forma financial information
provided.  Please be advised that although estimates were used to
determine the pro forma adjustments related to intangible assets,
the
amounts and any related assumptions should be disclosed in the pro
forma financial information in the Form 8-K.  In future filings,
please indicate the nature and amounts assigned to the various
categories of intangible assets acquired, as estimated to date,
and
disclose the useful lives used to calculate amortization
associated
with each category of intangibles. Also, in addition to disclosing
the amount of debt repaid, please disclose the amount of debt
obtained to fund the transaction and the interest rates used to
calculate any related pro forma adjustments to interest expense,
as
part of the Form 8-K pro forma adjustment assumptions.  Please
note
that all significant assumptions used to calculate pro forma
adjustments should be disclosed in notes to the pro forma
financial
information.

* * * * * * * * * * * * * * * * * * * * * * *

As appropriate, please respond via EDGAR to these comments within
10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested supplemental information.
Please
understand that we may have additional comments after reviewing
your
responses to our comments.

You may contact Claire Erlanger at 202-551-3301 or me at 202-551-
3813
if you have questions.

								Sincerely,

								Linda Cvrkel
								Branch Chief
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Mr. Carl G. Schmidt
Lee Enterprises
February 8, 2006
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