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                  Suite 2800  1100 Peachtree St.

                  Atlanta
      GA 30309-4530

                  t
      404 815 6500  f 404 815 6555

                  www.KilpatrickStockton.com

                  July 14, 2009

                  direct dial 404 815
      6270

                  direct
      fax 404 541 3400

                  JStevens@kilpatrickstockton.com

      VIA Federal
Express

      U.S. Securities and Exchange
Commission

      Division
of Corporation Finance

      Mail Stop
4561

      Washington,
D.C.  20549

                    Attention:

                    Ms.
      Kathryn McHale, Staff Attorney

                    Re:

                    United
      Community Banks, Inc.

                    Form
      10-K for FYE December 31, 2008

                    Form 10-Q for March 31,
      2009

                    Response
      to Sec Comments dated April 28, 2009

                    File
      Number 0-21656

      Ladies
and Gentlemen:

      At the
request and on behalf of our client, United Community Banks, Inc. (the “Company”),
we re-submit this Supplemental Support Booklet in response to certain of the
comments set forth in the Staff’s comment letter dated April 28, 2009, as
indicated in our response letter dated May 14, 2009.  For reasons of
business confidentiality, we hereby request, on behalf of the Company, that the
Commission afford confidential treatment under the Freedom of Information Act to
the last page of this Supplemental Support Booklet, labeled as “Breakdown of
Nonperforming and ‘Adversely Classified’ Loans”.  Please note that the
exhibits are keyed to the Commission’s response letter dated April 28,
2009.  Please inform the undersigned promptly if any request is made
under the Freedom of Information Act for access to the “Breakdown of
Nonperforming and ‘Adversely Classified’ Loans”.

      The Staff
is requested to direct any further questions regarding the attached Supplemental
Support Booklet and this letter to the undersigned at (404) 815-6270 or my
colleague, Adwoa Awotwi at (404) 815-6613.  Thank you.

                      Sincerely,

                    /s/
      James W. Stevens

                      James
      W. Stevens

                  Cc:

                  Jimmy
      C. Tallent, United Community Banks, Inc.

                  Rex
      S. Schuette, United Community Banks, Inc.

                  Alan
      Kumler, United Community Banks,
Inc.

      United
Community Banks, Inc.

      Supplemental
Support Booklet

      July 14,
2009

Please
see the attached earnings announcement for our results for the first quarter of
2009.

          For
Immediate Release

          For
more information:

          Rex S.
Schuette

          Chief
Financial Officer

          (706)
781-2266

          Rex_Schuette@ucbi.com

          UNITED
COMMUNITY BANKS, INC. REPORTS

          NET
OPERATING LOSS FOR FIRST QUARTER 2009

                    ●

                      Provision
      for loan losses of $65 million exceeded charge-offs by $22
      million

                    ●

                      Allowance-to-loans
      ratio of 2.56 percent, up from 2.14 percent last
quarter

                    ●

                      Non-cash
      goodwill impairment charge of $70 million, or $1.45 per diluted  share, primarily
      due to stock price decline

                    ●

                      Severance
      costs of $2.9 million, or 4 cents per diluted share, related to
      reduction in
      work force

                    ●

                      Margin
      improvement of 38 basis points this quarter to 3.08
  percent

                    ●

                      Capital
      levels remain strong

          BLAIRSVILLE,
GA – April 23, 2009 – United Community Banks, Inc. (NASDAQ: UCBI) today reported
a net operating loss of $32 million, or 71 cents per diluted share, for the
first quarter of 2009. The net operating loss was primarily driven by higher
credit costs, including the $22 million build-up in the allowance for loan
losses.  Net operating loss does not reflect a $70 million non-cash
charge for impairment of goodwill and $2.9 million in severance costs relating
to a reduction in work force, both of which are considered non-recurring
expenses and therefore excluded from operating earnings. Including these
non-recurring expenses the net loss for the quarter was $103.8 million, or $2.20
per diluted share.

          “The $70
million goodwill impairment charge is a non-cash accounting adjustment to the
company’s balance sheet that does not affect cash flow or liquidity and has no
impact on our regulatory or tangible capital ratios,” stated Jimmy Tallent,
president and chief executive officer. “During the fourth quarter our stock
price traded well above tangible book value, and our goodwill test indicated no
impairment at year-end.   However, our stock price declined
sharply during the first quarter, as did those of most financial services
companies.  When we updated our impairment test as of March 31, 2009,
we had impairment of $70 million driven primarily by the stock price
decline.”

              1

          “The
recession and its effect on the housing and construction markets, particularly
in Atlanta, continued to drive credit quality issues in our loan portfolio,”
added Tallent.   “A rise in the level of classified and
non-performing assets, and deterioration in property valuations, led us to
increase our allowance by $22 million over net charge-offs.  While we
remain committed to moving through this credit cycle as quickly as possible, our
efforts have been hindered by this difficult environment.”

          Loans
were $5.6 billion at quarter end, down $335 million from a year ago and down $72
million on a linked-quarter basis, reflecting the company’s continued efforts to
reduce exposure to the residential construction market.  At March 31,
2009, residential construction loans were $1.4 billion, or 25 percent of total
loans, a decrease of $361 million from a year ago and $49 million from the
fourth quarter of 2008.

          Taxable
equivalent net interest revenue of $57.4 million reflected an increase of $5.5
million from last quarter and a decrease of $8.9 million from a year
ago.  The taxable equivalent net interest margin was 3.08 percent
compared with 2.70 percent for the fourth quarter of 2008, and 3.55 percent for
the first quarter of 2008.

          “In the
latter part of the fourth quarter, we were able to take several steps that
contributed to the expansion in our first quarter margin,” stated
Tallent.  “We improved our loan pricing and credit spreads, decreased
deposit interest rates and, with an overall improvement in liquidity, we were
able to let higher-cost time deposits and brokered deposits run
off.  We will continue to actively pursue strategies to improve our
margin, while balancing liquidity needs with our goal of maximizing pre-tax,
pre-provision earnings.”

              2

          “Core
deposits, excluding public funds, increased in every category this quarter
reflective of our new initiatives and programs for customer referrals and cross
selling,” stated Tallent.  “We added 21,918 new services this quarter,
an annual growth rate of 11 percent, that expanded customer relationships and we
opened 3,585 net new customer accounts.”

          The first
quarter provision for loan losses was $65 million, compared with $85 million for
the fourth quarter of 2008.  Net charge-offs for the first quarter
were $43.3 million compared with $74 million for the fourth quarter of
2008.  At quarter-end, non-performing assets totaled $334.5 million
compared with $250.5 million at December 31, 2008.  The ratio of
non-performing assets to total assets at the end of the first and fourth
quarters was 4.11 percent and 2.94 percent, respectively.  The
allowance for loan losses to total loans was 2.56 percent and 2.14
percent.

          “The
recession continued to negatively affect our credit quality, particularly within
our Atlanta residential construction portfolio,” Tallent said. “Although we have
seen some deterioration in other loan categories and markets, our principal
challenge remains in the residential construction portfolio.  The rise
in non-performing assets was driven primarily by continued weakness in the
Atlanta housing and construction markets, and to softened demand from
buyers.  We expect the challenges to continue in 2009 and the level of
charge-offs and non-performing assets to be elevated over historical
levels.  However, we will aggressively work through our problem
credits and pursue the best economic outcome for our company in each
instance.”

          Fee
revenue of $12.8 million was up $2.1 million from the fourth quarter, but down
$1.4 million from the first quarter of 2008.  Service charges and fees
on deposit accounts of $7.0 million reflected a $779,000 decrease from a year
ago due to lower activity and fewer transaction charges.  Consulting
fees were down $786,000 from last year primarily due to the consulting
assistance provided to United for a company-wide initiative to improve
efficiency and profitability.  Consulting fees were further affected
by weakness in the financial services industry that hindered sales efforts and
delayed consulting contracts.  Mortgage loan fees of $2.7 million were
up $688,000 due to a record high level of refinancing activity.

              3

          Operating
expenses, before the recognition of goodwill impairment and severance costs,
were $52.6 million reflecting an increase of $5.0 million from the first quarter
of 2008 and at the same level as the fourth quarter of 2008.  The
increase year over year was primarily due to higher foreclosed property costs of
$3.4 million and an increase in FDIC insurance premiums of $1.4
million.  For the first quarter of 2009, salaries and employee benefit
costs of $28.8 million were at the same level as a year ago.  First
quarter 2009 staff costs did not reflect the reduction in work force of 191
staff, since most of the reduction in work force occurred at the end of the
quarter with the remainder transitioning through the
year-end.  Severance and related benefit costs of $2.9 million were
related to the reduction in staff.

          “The
decision to reduce staff was among the most difficult in my 25 years at United,”
commented Tallent.  “Unfortunately, their departure came as a result
of economic conditions that were not within our control, but had a powerful
influence on our business decision for the reduction in staff.  We
expect to save $10 million in annual staff and benefit costs.  Also,
we have completed a company-wide performance improvement project with fee
revenue enhancements and expense savings of $7 million annually that should be
fully implemented by year-end.  We expect to realize over half of the
$17 million of annual savings this year.”

          The
effective tax rate for the first quarter of 2009 was 14 percent, compared to
35.5 percent for the first quarter of 2008.  “The tax rate was lower
this quarter because goodwill and the related impairment charge are not
recognized, nor deductible, for tax reporting purposes,” stated
Tallent.  “Also affecting the first quarter tax rate was a $2.3
million net reserve for deferred tax assets relating to state tax credits that
are expected to expire unused.  The projected effective tax rate for
the balance of 2009 is 38 percent.”

          United
continues to maintain a strong capital position.  At March 31, 2008,
the company’s regulatory capital ratios were as follows: Tier I Risk-Based
Capital of 10.9 percent; Leverage of 7.9 percent; and, Total Risk-Based of 13.6
percent.  Also, the average tangible equity to assets ratio was 8.3
percent and the average tangible common equity to assets ratio was 6.1
percent.

              4

“While we
continue to aggressively dispose of problem credits and improve our margin, we
have been pursuing ways to build on the growth opportunities identified
throughout our markets,” Tallent said.  “A key part of this plan was
recently launched with the reorganization of our Atlanta region that enables us
to more efficiently pursue, and better meet the needs of, small business and
commercial customers.  This new structure and redeployed team will not
only increase and deepen our current customer relationships, but also expand our
commercial and small business lending capabilities. Also, they will contribute
to additional core deposits as well as further rebalance our loan portfolio,
while reducing our exposure to any one segment of the market.  Even
though we will be using considerable resources to address the credit challenges
for the remainder of the year, we will continue to plan ahead and position
ourselves to capitalize on new opportunities across our footprint as the economy
improves.”

          Conference
Call

          United
Community Banks will hold a conference call today, Thursday, April 23, 2009, at
11 a.m. ET to discuss the contents of this news release and to share business
highlights for the quarter. The telephone number for the conference call is
(877) 741-4240 and the pass code is “UCBI.” The conference call will also be
available by web cast within the Investor Relations section of the company's web
site at www.ucbi.com.

          About United Community
Banks, Inc.

          Headquartered
in Blairsville, United Community Banks is the third-largest bank holding company
in Georgia. United Community Banks has assets of $8.1 billion and operates 27
community banks with 107 banking offices located throughout north Georgia, the
Atlanta region, coastal Georgia, western North Carolina and east Tennessee. The
company specializes in providing personalized community banking services to
individuals and small to mid-size businesses. United Community Banks also offers
the convenience of 24-hour access through a network of ATMs, telephone and
on-line banking. United Community Banks common stock is listed on the Nasdaq
Global Select Market under the symbol UCBI. Additional information may be found
at the company’s web site at www.ucbi.com.

              5

          Safe
Harbor

          This
news release contains forward-looking statements, as defined by Federal
Securities Laws, including statements about financial outlook and business
environment. These statements are provided to assist in the understanding of
future financial performance and such performance involves risks and
uncertainties that may cause actual results to differ materially from those in
such statements. Any such statements are based on current expectations and
involve a number of risks and uncertainties. For a discussion of some factors
that may cause such forward-looking statements to differ materially from actual
results, please refer to the section entitled “Forward-Looking Statements” on
page 3 of United Community Banks, Inc.’s annual report filed on Form 10-K with
the Securities and Exchange Commission.

          # #
#

          (Tables
Follow)

              6

                                                                                                                                                          UNITED
      COMMUNITY BANKS, INC.

                                                                                                                                                          Financial
      Highlights

                                                                                                                                                          Selected
      Financial Information

                                                                                                                                                          First