SecProbe.io

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Mail Stop 0407
      						March 15, 2005

Via U.S. Mail and Fax (404) 261-9607

Mr. Robert S. Prather, Jr.
President and Chief Executive Officer
Bull Run Corporation
4370 Peachtree Road,
Atlanta, GA 30319

	RE:	Bull Run Corporation
      Form 10-K for the fiscal year ended August 31, 2004
		Form 10-Q for the period ended November 30, 2004
		File No. 0-9385

Dear Mr. Prather:

      We have reviewed your supplemental response letter dated
February 23, 2005 as well as the above referenced filings and have
the following additional comments.  As noted in our comment letter
dated February 1, 2005, we have limited our review to your
financial
statements and related disclosures and will make no further review
of
your documents.  As such, all persons who are responsible for the
adequacy and accuracy of the disclosure are urged to be certain
that
they have included all information required pursuant to the
Securities Exchange Act of 1934.  Please address the following
comments in future filings.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a future
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so that we may better understand
your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Bull Run Corporation
March 15, 2005

Form 10-K for the year ended August 31, 2004

1. Please refer to the information provided under the fourth
paragraph of your response to comment 7, in which you indicate how
overall assessment for reasonableness of results of impairment
testing was done.  Tell us why you believe that you should exclude
long term debt when you calculate the fair value and carrying
value
of the net assets of the Company. Also, it is unclear how you
determined the market value of the company`s common stock if you
stated in the first paragraph that there are no quoted market
prices
available.  We may have additional comments after review of your
response.

Revenue Recognition and Rights Fee Expenses, page 39

2. Please refer to the responses to comments no. 8 and 9.  In
future
filings please expand the disclosure in the note to include all
relevant information that you have provided in the responses.

Goodwill and other Long-Lived Assets, page 41

3. We have reviewed your response to comment no. 11 and we believe
that the customer relationships should be amortized based on the
contractual provisions.  Tell us how the 16-year average life uses
to
amortize the customer relationships compare with the contractual
life.  Further,  tell us why you believe  your accounting basis
for
amortizing the customer relationships over a 16-year average life
meets the requirements of paragraph 11 of SFAS no. 142.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested supplemental information.  Please file your response
letter
on EDGAR.  You may contact Gopal Dharia, Staff Accountant, at
(202)
942-1973 or Ivette Leon, Senior Staff Accountant, at (202) 942-
1982
if you have questions regarding comments on the financial
statements
and related matters.  Please contact me at (202) 942-1990 with any
other questions.

							Sincerely,

							Larry Spirgel
							Assistant Director

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