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CORRESP
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                        201 N. Harrison St

                        Carl G. Schmidt

                        Davenport, IA 52801

                        Vice President, Chief Financial

                        www.lee.net

                        Officer and Treasurer

                        (563)383-2179

                        Fax: (563)327-2600

                        carl.schmidt@lee.net

        March 26, 2010

        Ms. Linda Cvrkel

        Branch Chief

        Securities and Exchange Commission

        100 F Street, N.E.

        Washington, D. C. 20549

                        Re:

                        Lee Enterprises, Incorporated

        Form 10-K for the year ended September 27, 2009

        Filed December 11, 2009

        File No. 001-06227

        Dear Ms. Cvrkel:

        The following is in response to your March 12, 2010 letter, which was received via facsimile on the same day.

        Form 10-K for the year ended September 27, 2009.

        Comment 1 – Item 1A. Risk Factors

        Staff Comment:

        We note that you indicate this is a discussion of certain of the most significant risks and that other factors, both known and unknown, may cause results to differ. In future filings, all material risks should be described. If risks are note (sic) deemed material, do not reference them in future filings.

        Response:

        The Company believes it has described all known significant risks. In future filings, the Company will clarify the applicable language.

        Comment 2 – Item 1A. Risk Factors

        Staff Comment:

        Refer to the subheadings provided in this section. In future filings, please provide a sub- caption 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.

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        Response:

        The Company will comply with this requirement in future filings.

        Comment 3 – Signatures

        Staff Comment:

        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 signing in more than one capacity, please indicate each capacity in which he has signed. Refer to General Instructions D.2. for Signatures on Form 10-K.

        Response:

        The Company is uncertain of the intent of the Staff’s comment. The Company’s Chief Financial Officer is its “Principal Financial and Accounting Officer” as disclosed.

                        Management's Discussion and Analysis

        Comment 4 – Overall Results, page 26

        Staff Comment:

        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 disclosure 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 nonrecurring in nature, we would not expect similar debt financing cost, or other adjustments to be incurred over the last three year period. Please explain to us why you believe it is appropriate to disclose that the adjustments to your non- GAAP financial measures are "non-recurring" in nature. If these adjustments are not appropriately considered
        "non-recurring" in nature, provide us with and include in future filings, an explanation of the substantive reasons why management believes it is useful to include these adjustments in the non-GAAP financial measures. Your disclosure should also be revised to eliminate the reference to the "non-recurring" nature of the adjustments.

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        Response:

        The components of “other, net” adjustments to reported results are as follows:

                        (Thousands)

                        2009

                        2008

                        2007

                        Curtailment gains:

                        Company

                        -

                        -

                        (3,731)

                        TNI

                        (667)

                        -

                        (1,037)

                        Workforce adjustments and transition costs:

                        Company

                         6,651

                         3,428

                        -

                        MNI

                        266

                        774

                        -

                        TNI

                        598

                         261

                        -

                        Early retirement programs

                        -

                        -

                        7,962

                         6,848

                          4,463

                        3,194

        Such adjustments have been reported as separate line items in the related presentation in previous years but were combined in 2009 to simplify the presentation. Such items are also generally reported separately in the Company’s Consolidated Statements of Operations and Comprehensive Income (Loss).

        The Company’s adjusted net income and adjusted earnings per common share present non-GAAP adjustments to reported results for both “. . . unusual matters (emphasis added) and those of a substantially non-recurring nature . . .” as discussed on page 19. We agree with the Staff that amortization of debt financing costs is not generally
        considered to be non-recurring. However, in 2009, the Company incurred substantial debt financing costs in connection with a comprehensive restructuring of its debt, certain of which costs were reported as an expense. 2009 debt financing costs charged to expense were five times the 2008 level, a difference of almost $14 million, or $0.20 per share. The Company considered this to be “unusual”. The restructuring event and related spike in financing costs may also be considered
        by some as non-recurring. Accordingly, such costs were identified for purposes of the presentation as the impact on the Consolidated Financial Statements was significant.

        Notes to the Financial Statements

        Comment 5 – Note 6, Goodwill and Other Intangible Assets, page 64

        Staff Comment:

        We note your disclosure that in 2008 you recorded a reduction to goodwill totaling $25,098,000 to reflect a correction 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 appropriate to adjust the goodwill balance during fiscal 2008.

        Response:

        The adjustment to goodwill resulted from reversal of a deferred income tax liability related to tax deductible goodwill that was recorded by the Company’s Pulitzer Inc. subsidiary prior to its acquisition by the Company. This liability should have been eliminated upon the acquisition of Pulitzer in 2005 but was not discovered until 2008. Reversal of the liability in 2008 reduced goodwill and deferred
        income tax liabilities and had no impact on the amount of net loss recognized, stockholders’ equity or cash flows. The reversal of the amounts in

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        2005 would have resulted in the identical impact in purchase accounting. Due to the significant amount ($909 million) of goodwill impairment charges and related reversal of deferred taxes recognized in 2008, the reversal, as recorded, was not considered to be material to the Consolidated Financial Statements.

        Comment 6 – Note 7, Debt, page 65

        Staff Comment:

        We note your disclosure that the Company 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.

        Response:

        The identified charges are related to several events, none of which was considered to be a debt extinguishment. Capitalized costs represent (1) fees to lenders in conjunction with the 2009 Amendments in accordance with FASB ASC 470-50-40-17b; and (2) third party costs related to amendment of the Company’s revolving credit facility in February 2009, the amount of which was not reduced as a result of the
        amendment, in accordance with FASB ASC 470-50-40-21b.

        Costs charged to expense primarily represent third party costs related to amendment of the Company’s A Term Loan and Pulitzer Notes under the 2009 Amendments, in accordance with FASB ASC 470-50-40-18b. Third party costs related to the 2009 Amendments were allocated between the Company’s A Term Loan and revolving credit facility for capitalization purposes based upon the amount of the commitment.
        This allocation resulted in approximately two-thirds of such costs related to the Credit Agreement being charged to expense. All third party costs related to the Pulitzer Notes were charged to expense.

        The following table summarizes costs incurred:

                        (Thousands)

                        Capitalized

                        Expense

                        Credit Agreement:

                        A Term Loan:

                        Fees to Lenders

                         7,828

                        -

                        Third Party Costs

                        -

                         5,961

                        Revolving Credit Facility:

                        Fees to Lenders

                         3,770

                        -

                        Third Party Costs

                         3,004

                        -

                        Pulitzer Notes:

                        Fees to Lenders

                        930

                        -

                        Third Party Costs

                        -

                         3,440

                        Other

                         1,128

                        Total

                         15,532

                          10,529

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        Comment 7 – Note 8, Interest Rate Exchange Agreements, page 69

        Staff Comment:

        We note your disclosure that until 2009, you accounted for interest rate exchange agreements as cash flow hedges, and then 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.

        Response:

        Substantially all of the Company’s hedging instruments were approaching their maturity in 2009 and matured after the end of the fiscal year in November 2009. The Company marked such instruments to market as the effect of the change in designation was not material to the Consolidated Financial Statements. The Company, accordingly, ceased to perform the required evaluation required to consider such
        instruments as hedges. The Company will comply with this requirement in future filings to the extent such disclosure is considered to be material.

        Comment 8 – Note 13, Stock Ownership Plans, page 78

        Staff Comment:

        We note your disclosure of the weighted average assumptions used in the Black-Scholes model for options granted. In addition 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 expected term of share options, provide a discussion of the
        method used to incorporate the contractual term of the instruments and employees' expected exercise 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).

        Response:

        No stock options were granted in 2008 (most were cancelled as disclosed) and the cumulative amount of expense to be recognized in the years 2009 to 2012 for stock options granted in 2009 is approximately $1.2 million. The Company will comply with this requirement in future filings to the extent stock option activity is considered to be material.

        Comment 9 – Note 15, Fair Value of Financial Instruments, page 82

        Staff Comment:

        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 beginning 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 earnings (or changes in net assets), and a description

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        of where those gains or losses included in earnings (or changes in net 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 example, 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).

        Response:

        The only financial instrument as of September 27, 2009 measured using Level 3 inputs also originated in 2009. The Company will comply with this requirement in future filings to the extent such disclosure is considered to be material.

        Comment 10 – Note 19, Commitments and Contingent Liabilities, page 84 - Redemption of PD LLC Minority Interest, page 85

        Staff Comment:

        We note your disclosure that in February 2009, in conjunction with the Notes Amendment, PD LLC redeemed the 5% interest 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 between the Redemption Agreement that was executed in February 2009 and the "2010 Redemption". 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.

        Response:

        The determination of the amount of the Herald Value was based on an estimate of fair value. In 2009, the Company utilized both market and income-based approaches to determine the Herald Value. Both approaches subtract the balance of debt and apply a 10% (of fair value) factor to determine a final estimate of the Herald Value. In 2009, the market-based approach resulted in a negative value, so the
        income-based approach was weighted more heavily.

        The Company was assisted by a third party valuation expert in the determination of certain of