SEC Comment Letter for CBL & ASSOCIATES PROPERTIES INC (CBL) (CIK 0000910612) (CBL) — Feb 22, 2007

CBL & ASSOCIATES PROPERTIES INC (CBL) (CIK 0000910612)
Date: Feb. 22, 2007 · CIK: 0000910612 · Accession: 0000000000-07-009388

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Document Type

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File numbers found in text: 001-12494

Date

February 22, 2007

Author

Robert Telewicz

Form

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Company

CBL & ASSOCIATES PROPERTIES INC (CBL) (CIK 0000910612)

Letter

Mail Stop 4561 February 22, 2007 Charles B. Lebovitz 2030 Hamilton Place Blvd, Suite 500 Chattanooga, TN 37421

Re: CBL & Associates Properties, Inc. Form 10-K for Fiscal Ye ar Ended December 31, 2005 Filed March 15, 2006 Forms 10-Q for Fiscal Quarters E nded March 31, 200 6 and June 30, File No. 001-12494

Dear Mr. Lebovitz:

We have completed our review of your Form 10-K and related filings and do not, at this time, have any further comments.

You may contact Yolanda Crittendon, Sta ff Accountant, at (202) 551-3472 or the undersigned at (202) 551-3438 if you have questions.

Sincerely,
Robert Telewicz
Senior Staff Accountant

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Mail Stop 4561
February 22, 2007

Charles B. Lebovitz
2030 Hamilton Place Blvd, Suite 500
Chattanooga, TN 37421

Re: CBL & Associates Properties, Inc.
  Form 10-K for Fiscal Ye ar Ended December 31, 2005
  Filed March 15, 2006
Forms 10-Q for Fiscal Quarters E nded March 31, 200 6 and June 30,
2006
  File No. 001-12494

Dear Mr. Lebovitz:

We have completed our review of your Form 10-K and related filings and do not,
at this time, have any further comments.

You may contact Yolanda Crittendon, Sta ff Accountant, at (202) 551-3472 or the
undersigned at (202) 551-3438 if you have questions.

Sincerely,

Robert Telewicz
Senior Staff Accountant

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