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[The St. Joe Company Letterhead]

Direct Dial: 904-301-4346

Direct Fax: 904-301-4201

E-Mail: mregan@joe.com

December 16, 2005

VIA FACSIMILE AND EDGAR

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, DC 20549

Attention: Steven Jacobs (Mail Stop 4561)

    Re:

    The St. Joe Company

Form 10-K for Fiscal Year Ended December 31, 2004

Form 10-Q for Fiscal Quarter Ended March 31, 2005

Form 10-Q for Fiscal Quarter Ended June 30, 2005

SEC File No. 1-10466

Dear Mr. Jacobs:

This letter responds to a comment by the staff of the Securities and Exchange Commission (the
“Commission”) contained in the letter (the “Comment Letter”) dated December 7, 2005, from you to
Peter S. Rummell, the Chairman and Chief Executive Officer of The St. Joe Company (the “Company”).
For ease of reference, we have reproduced below the full text of the staff’s comment, which is
followed by the Company’s response.

Form 10-Q for the Fiscal Quarter Ended September 30, 2005

Note 3 – Discontinued Operations, page 9

We have reviewed your response to prior comment two. Please tell us how you applied the criteria
set forth in paragraph 42 of SFAS 144 and EITF 03-13 in determining that Advantis’ results of
operations should be reported in discontinued operations. Specifically, please address how you
considered your continued relationship with GVA Advantis, the new entity, as disclosed in your Form
8-K filed October 25, 2005.

In accordance with SFAS 144 paragraph 42 and EITF 03-13, Company management has assessed (1)
whether the operations and cash flows of Advantis have been or will be eliminated from the
Company’s continuing operations, and (2) whether the Company will have any significant involvement
in the operations of Advantis subsequent to the date of sale.

The Company will continue to have direct cost generating activities with Advantis for the next
three years in the form of management fees paid to Advantis for the management of certain

Securities and Exchange Commission

December 16, 2005

Page 2

Company properties as well as commissions paid to Advantis upon the sale of certain Company land.
These ongoing cost generating activities are not considered significant by Company management.
Historically, intercompany revenues received by Advantis from the Company were approximately 5% of
Advantis’ annual total cash outflows. Management expects future cash outflows from the Company to
Advantis to be less than 5% of Advantis’ annual total cash outflows. Management believes that this
level of cash outflows is not significant to either party.

From a cash inflows standpoint, the Company is receiving fees from Advantis for certain information
technology services. The Company has agreed to provide these services to Advantis for a limited
period of time to facilitate systems migration after the sale transaction. The amounts paid for
such services, however, are not significant to either Advantis or the Company.

In assessing the question of significant continuing involvement in the operations of Advantis, the
Company concluded that it does not have the ability to significantly influence the operating or
financial policies of Advantis. The Company retains no ownership interest in Advantis and believes
that the operations to be conducted between the Company and Advantis are not significant to the
overall operations of Advantis as discussed above. Although the common stock of Advantis is
pledged to the Company to secure the promissory note received as part of the sale proceeds (which
we believe to be a common term under an unsecured lending agreement), the terms of the security
agreement do not provide the Company with any means to significantly influence the operating or
financial policies of Advantis.

At your request, the Company also hereby affirms the following:

    •

    The Company is responsible for the adequacy and accuracy of the disclosure in the
filings;

    •

    staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filings; 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.

If you have any questions or comments regarding the foregoing, please contact me at your
convenience at 904-301-4346.

    Sincerely,

    /s/ Michael N. Regan

    Michael N. Regan

    Senior Vice President – Finance and Planning

(Principal Accounting Officer)

    cc:

    Amanda Sledge, Commission Staff Accountant

Christine M. Marx, General Counsel and Corporate Secretary