SecProbe.io

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Mail Stop 3561
      							July 28, 2005

Via U.S. Mail and Fax (504) 729-1436
Mr. Thomas M. Kitchen
Chief Financial Officer
Stewart Enterprises Inc.
1333 South Clearview Parkway
Jefferson, Louisiana  70121

	RE:	Stewart Enterprises, Inc.
      Form 10-K for the Fiscal Year Ended October 31, 2004
		Filed January 11, 2005

		Form 10-Q
		For the Quarterly Period Ended January 31, 2005

                	Form 10-Q
		For the Quarterly Period Ended April 30, 2005
      File No.  1-15449

Dear Mr. Kitchen:

      We have reviewed your supplemental response letter dated
July
19, 2005 as well as the above filings and have the following
comments.   Where indicated, we think you should revise your
documents in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
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 information so 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.

Form 10-K for the Fiscal Year Ended October 31, 2004

Item 1. Business, page 2

1. We note your response to our prior comment 1 under Item 2(1).
Tell us in detail what criteria you did not meet for sale and
leaseback accounting and whether you accounted for the related
transaction under the deposit or financing method. Refer to
paragraphs 7 and 10 of SFAS 98.

Notes to Consolidated Financial Statements

(24) Segment Data, page 104

2. We note your response to our prior comment 7, including your
analysis of SFAS 131 and certain supplemental reports provided to
your CODM and the Board of Directors.  Although financial and non-
financial metrics are reported for each product line (funeral and
cemetery), we note that key metrics for your funeral and cemetery
businesses are provided to the Board by geographic division.
Although product (business) objectives, standards, and metrics are
set centrally, implementation is performed at the divisional level
and measurement of actual performance (against plan, or on a year-
over-year basis or competitive analysis basis) is reported to the
CODM and BOD  at that level. The Company`s current segment
presentation for external reporting does not appear to be
representative of how the operations are managed and reviewed by
the
CODM.  We therefore continue to believe that geographic divisions
constitute your operating segments. Please revise your segment
presentation to comply with the "management approach" as described
in
SFAS 131.

3. Please disclose the items required by paragraph 31 of SFAS 131.

4. We note your response to our prior comment 8. We believe that
you
currently aggregate geographic operating segments based on product
line (funeral and cemetery).  However, the supplemental
information
that you provided based on 2004 fiscal year results indicates that
geographic segments have dissimilar economic characteristics by
virtue of their disparate average gross margins.  Demonstrate how
you
evaluated whether the operating segments have similar economic
characteristics.  Your response should include how you considered
similarities, if any, in their long-term financial performance in
your decision to aggregate.  Please advise or revise.

5. We note your response to our prior comment 9.  Please tell us
if
you considered whether an "area" (as managed by an area Vice
President within each geographic division), a "cluster" (page 9 of
the Form 10-K), or an individual cemetery or funeral business
constitutes a reporting unit.    Specifically tell us in your
response whether goodwill is recoverable from the deemed reporting
unit.  Refer to paragraph 30 of SFAS 142 and D-101.

Form 10-Q for the quarterly period ended January 31, 2005

Notes to Condensed Consolidated Financial Statements

(13) Long-term Debt, page 39

6. We note your response to our prior comment 10.  Please
reiterate
your representation based on your amended filing.

*    *    *    *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please file your cover
letter
on EDGAR.  Please understand that we may have additional comments
after reviewing your amendment and responses to our comments.

      You may contact Kathryn Jacobson, Staff Accountant, at (202)
551-3365 or Ivette Leon, Assistant Chief Accountant, at (202) 551-
3351 if you have questions regarding comments on the financial
statements and related matters.  Please contact Al Pappas at (202)
551-3378 or me at (202) 551-3810 with any other questions.

							Sincerely,

							Larry Spirgel
							Assistant Director

c.c.  Dionne M. Rousseau, Partner
        Jones, Walker, Waechter, Poitevant, Carrere & Denegre,
L.L.P.
??

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