SecProbe.io

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						April 6, 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
	Form 10-Q for the quarterly period ended December 30, 2005
	Commission file #: 001-06227

Dear Mr. Schmidt:

We have reviewed your March 24, 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

Note 2. Acquisitions

1. We note your supplemental letter detailing historical attrition
rate information but do not believe that it adequately addresses
the
concerns raised in our prior comment number 2. Please explain to
us
why you believe it was appropriate to use an attrition rate based
on
information from only one period (2003 to 2004).  Additionally,
please provide us information on the actual attrition rates of
these
advertisers since the acquisition in June 2005 and tell us how
that
would have affected your calculation of the intangible asset as of
the date of the acquisition.  We may have further comment upon
receipt of your response.

2. Also, we note from the Company`s response that the useful lives
of
customer lists were further determined by the point at which 95%
of
the expected future value is achieved based on the cash flow
generated by such customer lists. Since it appears you will derive
more value from these customer lists in periods immediately
following
the acquisition than in subsequent periods, it appears that a
method
of amortizing the customer list intangibles which results in
increased amortization in earlier periods and lesser amortization
in
later periods may be more appropriate than the use of the
straight-
line method. Please tell us what if any consideration was given to
amortizing the customer relationship intangibles using a method
that
is based on the expected revenues or benefits to be derived from
the
customer list intangible. We may have further comment upon receipt
of
your response.

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

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 Linda Cvrkel at
202-551-3813 if you have questions.

								Sincerely,

								Linda Cvrkel
								Branch Chief
Mr. Carl G. Schmidt
Lee Enterprises
April 6, 2006
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