SEC Comment Letter for CBL & ASSOCIATES PROPERTIES INC (CBL) (CIK 0000910612) (CBL) — Jun 28, 2012

CBL & ASSOCIATES PROPERTIES INC (CBL) (CIK 0000910612)
Date: June 28, 2012 · CIK: 0000910612 · Accession: 0000000000-12-033861

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AI Filing Summary & Sentiment

Sentiment

Urgency

Document Type

Confidence

SEC Posture

Company Posture

Summary

Reasoning

Date

December 31, 2011

Author

/s/ Daniel L. Gordon

Form

UPLOAD

Company

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

Letter

June 28 , 2012 Via E -mail Mr. Stephen D. Lebovitz President and Chief Executive Officer CBL & Associates Properties, Inc. 2030 Hamilton Place Blvd., Suite 500 Chattanooga, TN 37421

RE: CBL & Associates Properties, Inc. Form 10 -K for the Fiscal Year Ended December 31, 2011 Filed February 29, 2012 File No. 1 -12494

Dear Mr. Lebovitz:

We have completed our review of your filing . We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing 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. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicabl e rules require.

Sincerely,
/s/ Daniel L. Gordon

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June 28 , 2012

Via E -mail
Mr. Stephen D. Lebovitz
President and Chief Executive Officer
CBL & Associates Properties, Inc.
2030 Hamilton Place Blvd., Suite 500
Chattanooga, TN 37421

 RE: CBL & Associates Properties, Inc.
Form 10 -K for the Fiscal Year Ended December 31, 2011
  Filed February 29, 2012
  File No. 1 -12494

Dear Mr. Lebovitz:

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure  in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing 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.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicabl e rules require.

Sincerely,

 /s/ Daniel L. Gordon

Daniel L. Gordon
        Branch Chief

SecProbe.io