SecProbe.io

Mail Stop 3561
        March 12, 2010  Via Fax & U.S. Mail

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

Re: Lee Enterprises, Incorporated
 Form 10-K for the year ended September 27, 2009
Filed December 11, 2009
 File No. 001-06227

Dear Mr. Schmidt:

We have reviewed your filing and have the following comments.  Unless
otherwise indicated, we think you should revi se your document in future filings in
response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revisi on is unnecessary.  Please be as detailed as
necessary in your explanation.  In some of our comments, we may ask you to provide us
with information so we may better understand your disclosure.  Af ter reviewing this
information, we may raise additional comments.
  Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Please respond to confirm that such comments will be complied with, or, if
certain of the comments are deemed inappropr iate, advise the staff of your reason.  Your
response should be submitted in electronic form, under the label “corresp” with a copy to the staff.  Please respond w ithin ten (10) business days.
  Form 10-K for the year ended September 27, 2009

Item 1A.  Risk Factors

Mr. Carl G. Schmidt
Lee Enterprises, Incorporated
March 12, 2010 Page 2

1. We note that you indicate this is a discus sion of certain of the most significant
risks and that other factor s, both known and unknown, may cau se results to differ.
In future filings, all material risks shoul d be described.  If risks are note deemed
material, do not reference them in future filings.

2. Refer to the subheadings provided in this section.  In future filings, please provide
a subcaption that adequately describes each  of the risks discussed.  Each risk
should have its own subheading that adequately describes the risk that follows.
Refer to Item 1A. of Form 10-K, Item 503(c) of Regulation S-K and Rule 421(d)
of the Securities Act of 1933.
 Signatures

3. The report must also be signed on behalf  of the Registrant by its principal
financial officer and its controller or principal accounting officer in their respective capacities.  If someone is signi ng in more than one capacity, please
indicate each capacity in which he has si gned.  Refer to Genera l Instructions D.2.
for Signatures on Form 10-K.
 Management’s Discussion and Analysis

 – Overall Results, page 26

4. We note that net income, as adjusted amount includes an adjustment in both fiscal
2009 and 2008 for “other, net.”  Please tell us the nature of these “other” amounts
and why you believe it is appropriate to  include them in a non-GAAP financial
measure.  Also, we note from your disclosu re on page 32 that debt financing costs
have been included as an adjustment in  your non-GAAP measure “net income, as
adjusted” in fiscal years 2007, 2008 and 2009 .  In light of the fact that you
disclose on page 19 that your non-GAAP adjustments are substantially non-recurring in nature, we would not expect  similar debt financ ing cost, or other
adjustments to be incurred over the last three year period.  Pl ease explain to us
why you believe it is appropriate to disclose that the ad justments to your non-
GAAP financial measures are “non-recurring” in nature.  If these adjustments are not appropriately considered  “non-recurring” in natu re, provide us with and
include in future filings , an explanation of the substantive reasons why
management believes it is useful to in clude these adjustments in the non-GAAP
financial measures.  Your disclosure s hould also be revised to eliminate the
reference to the “non-recurring” na ture of the adjustments.
 Notes to the Financial Statements

 Note 6. Goodwill and Other Intangible Assets, page 64

Mr. Carl G. Schmidt
Lee Enterprises, Incorporated
March 12, 2010 Page 3

5. We note your disclosure that in 2008 you recorded a reduction to goodwill
totaling $25,098,000 to reflect a correctio n to the original 2005 purchase
accounting of Pulitzer.  Please explain to us  the nature of the correction of this
error and tell us why you believe it is a ppropriate to adjust the goodwill balance
during fiscal 2008.

Note 7. Debt, page 65

6. We note your disclosure that the Comp any paid fees to the Lenders and
Noteholders for the 2009 Amendments and Notes Amendment, which along with the related legal and financial advisory expenses, totaled $26,061,000, of which $15,500,000 were capitalized.   Please tell  us how you accounted for both the
capitalized and the expensed fees in accordance with the guidance in FASB ASC
470-50-40 paragraphs 17, 18 and 21 (EITF 96-19 and 98-14), as applicable.
 Note 8. Interest Rate Exchange Agreements, page 69

7. We note your disclosure that until 2009, you accounted for interest rate exchange
agreements as cash flow hedges, and th en in 2009, you marked all interest rate
exchange agreements to market and recognized interest expense of $268,000. Please explain to us, and disclose in future filings, the reason for the change in your accounting for these interest rate exchange agreements.
 Note 13. Stock Ownership Plans, page 78

8. We note your disclosure of the weighted average assumptions used in the Black-
Scholes model for options granted.  In add ition to disclosing the weighted average
assumptions for options granted during the year, please revise future filings to include a description of the methods used to estimate or determine those
assumptions.  For example, for the exp ected term of share options, provide a
discussion of the method used to inco rporate the contractual term of the
instruments and employees’ expected ex ercise and postvesting employment
termination behavior into the fair value of the instrument.  See guidance in FASB
ASC 718-10-50-2.f.2 (paragraph 240(e)(2) of SFAS No. 123R).

Note 15. Fair Value of Financial Instruments, page 82

9. We note your disclosure that the Herald  Value – liability is measured using
significant unobservable inputs (Level 3).  For all assets and liabilities measured
at fair value on a recurring basis using Level 3 inputs, please revise future filings
to include disclosure of a reconciliation of the be ginning and ending balances,
separately presenting changes during the period attributable to the following:
(1) Total gains or losses for the period (realized and unrealized), segregating those gains or  losses included in earn ings (or changes in net

Mr. Carl G. Schmidt
Lee Enterprises, Incorporated
March 12, 2010 Page 4

assets), and a description of wher e those gains or losses included in
earnings (or changes in ne t assets) are reported in the statement of income
(or activities)
(2) Purchases, sales, issuances, and settlements (net) (3) Transfers in and/or out of Level 3 (for exam ple, transfers due to
changes in the observability of significant inputs)
See guidance in FASB ASC 820-10-50-2.c  (paragraph 32 of SFAS No. 157).
 Note 19. Commitments and Contingent Liabilities, page 84

- Redemption of PD LLC Minority Interest, page 85

10. We note your disclosure that in Februa ry 2009, in conjunction with the Notes
Amendment, PD LLC redeemed the 5% inte rest in PD LLC and DS LLC.  In light
of the fact that the present value of the 2010 Redemption was approximately
$73.6 million at the time of redemption in February 2009, please tell us why you recorded a liability of $2.3 million at September 27, 2009 as an estimate of the
amount of the Herald Value to  be disbursed.  As part of your response, please tell
us the nature of any differences betw een the Redemption Agreement that was
executed in February 2009 and the “2010 Rede mption.”  Also, tell us the nature of
the assumptions used in the calculation or determination of the $2.3 million liability established at September 27, 2009.

Note 21. Quarterly Financial Data (Unaudited), page 87

11. We note from your disclosure in Note 14 th at subsequent to the quarter and year
ended September 28, 2008, you discovered an immaterial error in the valuation
allowance for deferred tax assets which a ffected the amount of net deferred tax
liabilities, the income tax benefit and earnings(loss) per share for the quarter
ended September 28, 2008.  Please note for future filings that  when the data
supplied in your note disclosing quarterly financial data varies from the amounts
previously reported on the Form 10-Q f iled for any quarter, your disclosure
should reconcile the amounts given with those previous ly reported and describe
the reason for the difference.  See Item 302(A)(2) of Regulation S-K.

Form 10-Q for the quarter ended December 27, 2009

Balance Sheet
Statements of Operations a nd Comprehensive Income (Loss)

12. We note from your presentation of minority interest on both the balance sheet and
statement of operations that it does not a ppear that you have adopted the guidance
in FASB ASC 810-10-45.  Please revise future filings accordingly.

Mr. Carl G. Schmidt
Lee Enterprises, Incorporated
March 12, 2010 Page 5

Note 6. Pension, Postretirement and Postemployment Defined Benefit Plans

13. We note your disclosure that in Decem ber 2009 you notified certa in participants
in your postretirement medical plans of changes to be made to the plans, including
increases in participant premium cost-s haring and elimination of coverage for
certain participants.  You also disclose  that these changes resulted in non-cash
curtailment gains of $31 million and re duced the benefit obligation by $31
million.  Please provide us more details as  to the nature of the changes made and
explain why you believe all changes repres ent a curtailment ra ther than both a
negative plan amendment and a curtailmen t.  Also, please e xplain to us how you
calculated the amount of the net curtailmen t gain to be recognized on the income
statement.  Include in your response th e amount of any unrecognized net actuarial
gain(loss) included in accumulated other comprehensive income at the time of the
curtailment.  If a portion of this transact ion is more appropriat ely classified as a
negative plan amendment, the effects of  the negative plan amendment should be
calculated before the determination of any gain/loss related to the curtailment is
made.  Please advise or revise accordingl y.  Also, please revise MD&A in future
filings to discuss the nature of this tr ansaction and how you ar e accounting for it.
Additionally, please tell us  why you believe it is appropriate to present the
curtailment gain as part  of operating income.
 Note 10. Fair Value Measurements, page 16

14. We note from your disclosure on page 17 that in 2009 you reduced the carrying
value of property and equipment no longer in use by $4,579,000 based on
estimates of the related fair value in the cu rrent market.  Please revise the notes to
the financial statements in future filings to include the disclosures required by FASB ASC 820-10-50-5 for any assets and liabilities measured at fair value on a
non-recurring basis.

Schedule 14A filed January 7, 2010

Compensation of Non-Empl oyee Directors, page 15

15. In future filings, please disclose all assumptions made in the valuation of awards
in the stock awards column of the tabl e by reference to a discussion of those
assumptions in your financial statements, f ootnotes to the financial statements, or
discussion in Management’s Discussion and Analysis.  See Instruction to Regulation S-K Item 402(k), which refers to Instruction 1 to Item 402(c)(2)(v)
and (vi).  Similarly revise your Summary  Compensation Table in regards to the
stock awards and option awards columns.   Refer to Instruction 1 to Item
402(c)(2)(v) and (vi) of Regulation S-K.

Mr. Carl G. Schmidt
Lee Enterprises, Incorporated March 12, 2010 Page 6

********

  We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:  ‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
‚ the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.   You may contact Claire Er langer at (202) 551-3301 or Jean Yu at (202) 551-3305
if you have questions regarding comments on the financial statements and related
matters.  Please contact me at ( 202) 551-3813 with any other questions.

Sincerely,

Linda Cvrkel Branch Chief

VIA FACSIMILE (563) 327-2600