SecProbe.io

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      August 31, 2005

Paul Buchschacher, Esq.
Vice President & General Counsel
D.R. Horton, Inc.
301 Commerce Street, Suite 500
Fort Worth, Texas 76102

Re:	D.R. Horton, Inc.
	Registration Statement on Form S-3
	Filed on August 11, 2005
	File No. 333-127461

Dear Mr. Buchschacher:

      We have limited our review of your filing to those issues we
have addressed on our 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 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.

General

1. At the time the company requests acceleration of this
registration
statement, the company should state that it has no present intent
to
make the first offering of securities promptly, and therefore will
be
making the offering on a delayed basis rather than in reliance on
Rule
430A.  Alternatively, the company should file a pre-effective
amendment to include all of the information about the securities
to be
offered, plan of distribution, a clean legality opinion and, if
applicable, an underwriting agreement with regard to any
securities to
be offered promptly, including in reliance on Rule 430A.

2. Where the offered securities involve the issuance of a novel or
complex security, we may have comments on the disclosure in the
prospectus supplements. If you are contemplating such an offering
and
would prefer review by us of the disclosure in the preliminary
form
rather than in the definitive prospectus supplement, the proposed
prospectus supplement should be submitted supplementally in
advance of
the intended offering date.

Calculation of Registration Fee Table

3. We reference footnote 2.  Please confirm that as shares of the
underlying common stock are offered and sold, you will count them
against the dollar amount of the securities remaining on this
registration statement.

Use of Proceeds, page 10

4. Confirm to us that your takedown supplements will disclose the
amount and terms of debt you may pay off with proceeds from the
sale
of the securities.

Description of Trust Preferred Securities, page 21

5. Please include a discussion of the accounting treatment, noting
how
the preferred securities will be reflected in the financial
statements
of the company and disclosing the assets of each trust.

Legal Opinion

6. Please confirm to us that you will file a clean opinion, either
in
post-effective amendment or in a Form 8-K, for each takedown.

Closing Comments

	As appropriate, please amend your filing in response to these
comments.  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 information.  Detailed cover letters greatly
facilitate
our review.  Please understand that we may have additional
comments
after reviewing your amendment and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have
made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

?	the company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal
securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division
of Corporation Finance in connection with our review of your
filing or
in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering of
the securities specified in the above registration statement.  We
will
act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.

	We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      Please contact Brigitte Lippmann at (202) 551-3713 or me at
(202) 551-3767 with any questions.

Sincerely,

Jennifer Hardy
Branch Chief

cc:	Irwin F. Sentilles, III, Esq.
	Gibson, Dunn & Crutcher LLP
	2100 McKinney Ave., Suite 1100
	Dallas, TX 75201

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Paul Buchschacher, Esq.
D.R. Horton, Inc.
August 31, 2005
Page 1

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

         DIVISION OF
CORPORATION FINANCE

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