SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010

July 25, 2006

Mr. J. Larry Sorsby
Executive Vice President and Chief Financial Officer
Hovnanian Enterprises, Inc.
10 Highway 35, P.O. Box 500
Red Bank, New Jersey 07701

 RE:  Form 10-K for the Fisc al Year ended October 31, 2005
  Forms 10-Q for the Quarters ended January 31, 2006 and
April 30, 2006
                     File No. 1-8551

Dear Mr. Sorsby:

  We have reviewed your response letter dated June 30, 2006 and have the
following additional comments.  If you disagree with a comment, we will consider your explanation as to why our comment is inappl icable or a revision is unnecessary.  Please
be as detailed as necessary in your explanation.

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

Form 10-K for the year ended October 31, 2005

1. We note that each of your communities is an operating segment and you believe that they can be aggregated because, among other things, they have similar
economic characteristics. You consider the internal rate of return to be the key
economic characteristic of a community and it is the key measure for resource
allocation and performance.

J. Larry Sorsby
Hovnanian Enterprises, Inc.
July 25, 2006 Page 2 of 3
However, we note that your internal ma nagement reports provided to the chief
operating decision maker, do in fact include revenue and gross margin by operating segment.  Therefore, it appears that operating results are also evaluated
based on revenues and gross margins.  If  actual revenue growth for homebuilding
operating segments have trended in a mate rially different manner or if gross
margin percentages are materially different  we believe that would be indicative of
dissimilar economic characteristics.  In addition, if the operating segments operate in different regulatory environments, we would also expect separate presentation of the operating segments.

Please explain how you calculate the internal rate of return.  Also, in order for us
to better understand your view, please provi de us with a report that summarizes,
for each operating segment during the past fi ve years, the following information:

- Actual Revenue;
- Actual Gross Margin;
- Actual Gross Margin Percentage; and
- Actual Internal Rate of Return.

2. You say that you do not compile revenue and gross margin data by product line as we have requested and that it is impr actical to do so given your current
information systems.  Based on your intern al management reports we noted that
the Meyers Group compiled a sales ranking of home builders by type of residence
that includes single-family detached homes, townhouses and condominiums and
that you appear to have provided sales data to them for each of these three housing categories.  In a ddition, as we stated in our previous comment, you
disclosed under results of operations on page 21 of your Form 10-K report that
gross margins before interest expense increased to 26.4% in 2005 compared to
25.5% in 2004 primarily due to the mix of  homes delivered both in terms of
geography as well as by type of home.  You also disclosed in an 8-K report issued
on September 7, 2005, that your outstanding performance during the 2005 third quarter was due to having the right produc t mix throughout each of your markets.
Based on these disclosures it appears th at revenue by product line is information
that is material to investors.  Pleas e provide the enterprise-wide product-line
revenue disclosures requir ed by paragraph 37 of SFAS 131 or provide us with
revenue and gross margin data for the last three years and through the current
interim period for single-family detached homes, townhouses, and condominiums so that we can assess the materiality of revenue and gross margin trends by
product line.

*    *    *    *

J. Larry Sorsby
Hovnanian Enterprises, Inc.
July 25, 2006 Page 3 of 3
        Please respond to these comments within 10 business days, or tell us when you will provide us with a response.  Please provi de us with a response letter that keys your
responses to our comments and provides a ny requested information.  Detailed letters
greatly facilitate our review .  Please file your response on EDGAR as a correspondence
file.  Please understand that we may have additional comments after reviewing your
responses to our comments.

        If you have any questions regardi ng these comments, please direct them to Gus
Rodriguez, Staff Accountant, at (202) 551-3752 or, in his absence, to the undersigned, at
(202) 551-3689.

         Sincerely,

            John Hartz
                                                            Senior Assistant Chief Accountant