SecProbe.io

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						May 5, 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 May 1, 2006 response letter and have the
following comments.  Please file an amended Form 10-K in response
to
our request for expanded or revised disclosure.  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

1. We have reviewed your responses to our prior comment numbers 1
and
2 but continue to believe that your use of weighted average useful
lives of 21 years for the advertiser lists acquired in the
Pulitzer
acquisition, when used in conjunction with the straight-line
method of
amortization, are not appropriate. In this regard, both the
historical
rates of amortization provided in your last response, and those
used
subsequent to the acquisition, are indicative that little if any
benefit will be generated from the advertiser lists in the later
portion of the 21 year useful lives being used for your advertiser
list. This conclusion is based upon the fact that since the date
of
the acquisition, through March 2006, a period of only a little
more
than a year, the Company has already lost between 10 and 20% of
the
customer list acquired based on your latest response.
Additionally, we
do not concur with the statement included in your response which
indicates that if attrition rates based on the latest full year of
information available were used, the value for the advertiser
lists
would decrease and goodwill recognized would increase by a
corresponding amount. Instead, we believe that the increased
attrition
rates would not only change the valuation of the intangible, but
would
also result in a significantly shortened useful life. Furthermore,
we
do not concur with your conclusion that the straight-line method
provides a better match to the expected future benefits to be
derived
from the advertising list. In this regard, we believe that the
expense
recognized should be matched to the benefit derived from the
intangible asset acquired, which should not include expected
revenue
growth as you have indicated in your response.

Given the above factors, please file an amended Form 10-K for the
year
ended September 30, 2005 to revise your amortization of the
customer
lists acquired in the Pulitzer acquisition to either use a shorter
useful life in line with your recent attrition rates, or to
recognize
the amortization of these assets on an accelerated basis. We
believe
these changes in amortization are necessary so that the customer
lists
acquired are amortized in the periods in which the related
benefits
from the list are derived.

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

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
May 5, 2006
Page 1

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