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The GEO Group, Inc.

August 4, 2005

VIA FEDERAL EXPRESS

Rufus Decker, Branch Chief

Division of Corporation Finance

United States Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549-0404

              Re:

    The GEO Group, Inc.

Form 10-K for the year ended January 2, 2005

Form 10-Q for the quarter ended April 3, 2005

Dear Mr. Decker:

     The GEO Group, Inc. (“GEO”), hereby responds to the comments of the staff (the “Staff”), as
set forth in the letter, dated July 18, 2005 (the “Letter”), with respect to GEO’s Form 10-K for
the year ended January 2, 2005 (the “Form 10-K”), and Form 10-Q for the period ended April 3, 2005
(the “Form 10-Q”).

     Please note that, for your convenience of reference, we have recited below each comment
included in the Staff’s Letter and provided GEO’s response to such comment immediately thereafter.

Form 10-K for Year Ended January 2, 2005

Comment applicable to your overall filing

    1.

    Where a comment below requests additional disclosures or other revisions, please show us in
your supplemental response what the revisions will look like. With the exception of the
comment below that specifically requests an amendment, all other revisions may be included in
your future filings.

    Where requested, we have provided below additional disclosures or other revisions similar to
those we intend to make in future filings in order to provide the Staff with guidance on
what our proposed revisions will look like. With the exception of Comment #22, with respect
to which we will file appropriate amendments to the Form 10-K and the Form 10-Q, we intend
to address all comments in the Letter in GEO’s future filings.

Rufus Decker, Branch Chief

Division of Corporation Finance

United States Securities and Exchange Commission

August 4, 2005

Page 2

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 15

    2.

    Please discuss and analyze the business reasons for the changes between periods in the
revenues and operating income of each of your segments. Please also discuss the impact of
significant non-cash credits and charges on operating income for each segment. For example,
some of the increase in operating income in the U.S. operations appears to be due to non-cash
credits of $1,150,000 in 2004 compared to non-cash charges of $8,600,000 in 2003. Please
refer to SEC Release 33-8350 for guidance.

    Although GEO operates in three business lines and in various geographic areas, GEO does not
believe that any of these business lines or geographic areas constitute separate reportable
segments pursuant to SFAS 131. With respect to GEO’s business lines, GEO’s primary business
line from which GEO has derived substantially all of its historical revenue and operating
income is the management and operation of privatized correctional and detention facilities.
The two other business lines in which GEO operates are the operation and management of state
mental health facilities and the provision of construction and design services, a business
line in which GEO typically engages to ensure that the facilities that GEO operates are
developed on-time and on-budget. Neither of these business lines is material to GEO’s
revenues or operating income. Because neither of these two latter business lines meets the
10% threshold for materiality to GEO’s overall business set forth in SFAS 131, GEO does not
believe that either of these two business lines constitute separate reportable segments as
defined in SFAS 131. As a result, GEO does not believe that the guidance for MD&A
disclosure on separate segments set forth in SEC Release 33-8350 applies to these business
lines. The table below illustrates the calculation of the 10% materiality test for
reportable segments with respect to each of GEO’s business lines:

    2004

    %

    2003

    %

    2002

    %

    Consolidated Revenue

    $
    614,548

    100.0
    %

    $
    567,441

    100.0
    %

    $
    517,162

    100.0
    %

    Revenues — mental health

    $
    39,318

    6.4
    %

    $
    37,622

    6.6
    %

    $
    35,980

    7.0
    %

    Revenue — construction

    $
    15,337

    2.5
    %

    —

    —

    —

    —

    Operating income

    $
    39,310

    100.0
    %

    $
    30,140

    100.0
    %

    $
    23,858

    100.0
    %

    Operating income — mental health

    $
    356

    0.9
    %

    $
    1,812

    6.0
    %

    $
    1,461

    6.1
    %

    Operating income — construction

    $
    311

    0.8
    %

    —

    —

    —

    —

    With respect to the geographic areas in which GEO operates, the two largest areas of
concentration are GEO’s U.S. and international operations. Although GEO recognizes that its
international operations likely meet the 10% materiality test for reportable segments, GEO
believes that these operations do not constitute a separate reportable segment because they
meet the aggregation criteria set forth in paragraph 17 of SFAS 131. The primary reasons
why GEO believes that its international operations meet the

Rufus Decker, Branch Chief

Division of Corporation Finance

United States Securities and Exchange Commission

August 4, 2005

Page 3

    criteria for aggregation with its domestic operations are the following: (i) in all of GEO’s
locations (including both U.S. and international locations), GEO enters into long term
contractual arrangements with governmental authorities to manage privatized prison and
detention centers; (ii) in all of GEO’s locations (including both U.S. and international
locations), the contracts are bid at similar gross margins and the operations are subject to
similar operating regulatory requirements; (iii) actual operating margins of international
and domestic operations fall within the parameters described by paragraph 17 of SFAS 131; (iv)
the nature of GEO’s services and methods of delivery are substantially the same in all
locations; (v) at all but two facilities that GEO operates, GEO manages all the essential
functions of the institution, including security operations, food service, medical/inmate
healthcare, facility maintenance and administrative; and (vi) in substantially all of the
facilities that GEO manages, most of the personnel working in the facility are GEO’s
employees, except for certain institutions where GEO outsources healthcare and/or food
service. Because GEO believes that its international operations meet the applicable
aggregation criteria, GEO does not believe that the guidance for MD&A disclosure on separate
segments set forth in SEC Release 33-8350 should apply to these operations.

Liquidity and Capital Resources, page 26

    3.

    Please disclose the impact of the projected benefit payments of $11,052,000 in 2005 on your
liquidity and the anticipated source of funds for the payments.

    GEO intends to disclose the impact of the projected benefit payments of $11,052,000 in 2005
on its liquidity and the anticipated source of funds for the payments by including language
similar to the following in future filings:

“We have entered into individual executive retirement agreements with our CEO and
Chairman, President and Vice Chairman, and Chief Financial Officer. These
agreements provide each executive with a lump sum payment upon retirement. Under
the agreements, each executive may retire at any time after reaching the age of 55.
Each of the executives reaches the eligible retirement age of 55 in 2005. None of
the executives have indicated their intent to retire. However, we have included the
expected payments as “due in less than one year” because each executive will be
eligible to retire beginning in 2005 and retirement may be taken at any time at the
individual executive’s discretion. In the event that all three executives were to
retire in the same year, we believe we will have funds available to pay the
retirement obligations from various sources, including cash on hand, operating cash
flows or borrowings under our revolving credit facility. Based on our current
capitalization, we do not believe that making these payments in any one period,
whether in separate installments or in the aggregate, would materially adversely
impact our liquidity.”

Rufus Decker, Branch Chief

Division of Corporation Finance

United States Securities and Exchange Commission

August 4, 2005

Page 4

     Contractual Obligations and Off Balance Sheet Arrangements, page 31

    4.

    Please revise your table of contractual cash obligations to include the following:

    (1)

    Estimated interest payments on your debt;

    (2)

    Estimated payments under interest rate swaps; and

    (3)

    Planned funding of pension and other post-retirement benefit
obligations. Because the table is aimed at increasing transparency of cash
flow, we believe these payments should be included in the table. Please also
disclose any assumptions you made to derive these amounts.

    GEO intends to revise its table of contractual cash obligations in future filings to include
(i) estimated interest payments on debt, and (ii) estimated payments under interest rate
swaps. GEO believes that its prior tables of contractual cash obligations have reflected
amounts attributable to planned funding of pension and other post-retirement benefit
obligations. GEO intends to continue this disclosure in future filings, and to also
disclose any key assumptions made in deriving the amounts of these obligations.

Financial Statements and Supplementary Data, page 46

    5.

    Audits of financial statements are performed in accordance with the standards of the Public
Company Accounting Oversight Board. Please revise management’s statement that the audit was
conducted in accordance with auditing standards generally accepted in the United States.

    GEO intends to revise future filings to state that its audits have been conducted in
accordance with auditing standards established by the Public Company Accounting Oversight
Board.

Consolidated Statement of Income, page 53

    6.

    You had a 50% ownership interest in Premier Custodial Group and have a minority investment in
South African Custodial Services. Your equity method investments appear to be significant in
2002 and possibly in 2003. Please provide us with your significance tests under Rule 3-09 of
Regulation S-X for 2002 and 2003. If in any period this investment was significant in excess
of the 20% level, separate financial statements are required to be included in your Form 10-K
for all periods presented. These separate financial statements must be audited for periods
that the 20% significance level was exceeded and may be unaudited for each other period.

Rufus Decker, Branch Chief

Division of Corporation Finance

United States Securities and Exchange Commission

August 4, 2005

Page 5

    GEO’s 50% former equity method investment in Premier Custodial Group, a joint venture based
in the United Kingdom (“PCG”), met the 20% significance test for 2002 and 2003. GEO
included separate audited financial statements for PCG for the fiscal years 2000, 2001 and
2002 in its Form 10-K/A, filed on June 30, 2003. GEO did not re-include the separate
audited financial statements for PCG for 2001 or 2002 in its subsequent Form 10-Ks. GEO did
not file separate audited financial statements for PCG for 2003 because, for various reasons
primarily related to the fact that GEO sold its interest in PCG on July 2, 2003, GEO sought
and received the Staff’s permission to exclude PCG’s financial statements for 2003 from its
Form 10-K filings. Copies of the letters pursuant to which GEO requested and received
relief from the Staff for this requirement will be provided to the Staff supplementally.

    GEO’s 50% equity method investment in South African Custodial Services, a joint venture
based in South Africa (“SACS”), has not previously met the 20% significance threshold which
would require GEO to file separate audited financial statements for SACS. GEO will continue
to monitor the significance of SACS to ensure the appropriate financial statements are
included in its filings for periods in which the significance level for SACS is met. The
following table sets forth the 20% significance test as applied to SACS for 2002, 2003 and
2004:

    2004

    %

    2003

    %

    2002

    %

    Consolidated total assets

    $
    480,146

    $
    510,533

    $
    402,658

    Investment in SACS

    $
    3,912

    0.8
    %

    $
    3,923

    0.8
    %

    $
    4,173

    1.0
    %

    GEO 50% share of SACS total assets

    $
    44,449

    9.3
    %

    $
    34,748

    6.8
    %

    $
    25,605

    6.4
    %

    Pre-tax income

    $
    26,453

    $
    78,163

    $
    24,968

    Equity earnings in SACS

    $
    —

    $
    (681
    )

    -0.9
    %

    $
    113

    0.5
    %

Consolidated Balance Sheets, page 54

    7.

    You disclosed that the number of shares of common stock issued and outstanding are the same,
yet you have 12,000,000 shares of treasury stock. Please revise the number of common stock
issued and outstanding to take account of the treasury common shares.

    GEO intends to revise future filings to state that the 12,000,000 shares of treasury stock
are issued but not outstanding.

Rufus Decker, Branch Chief

Division of Corporation Finance

United States Securities and Exchange Commission

August 4, 2005

Page 6

Consolidated Statements of Cash Flows, page 55

    8.

    The cash and cash equivalents amount on the balance sheet does not agree with the cash and
cash equivalents amount in the statements of cash flows apparently due to the discontinued
operations. Paragraph 7 of SFAS 95 requires cash and cash equivalents to be the same amount
in both statements. Please make the appropriate revisions.

    GEO intends to revise future filings to ensure that the amounts reflected as cash and cash
equivalents on the balance sheet and the statement of cash flows are the same, in accordance
with Paragraph 7 of SFAS 95.

Consolidated Statements of Shareholders’ Equity and Comprehensive Income, page 56

    9.

    Please disclose the reclassification adjustments of your derivative financial instruments in
the accumulated other comprehensive income (loss) column of your statement of stockholders’
equity. Please also disclose the reclassification adjustment related to the foreign currency
translation gain or loss realized upon the sale of your United Kingdom joint venture or
explain why the reclassification adjustment was not required. Please refer to paragraphs
18-21 pf SFAS 130 and paragraph 14 of SFAS 52.

    There was no ineffectiveness related to derivative financial instruments during 2004 and as
a result no amounts were reclassified into earnings for that period. However, a
reclassification adjustment on the derivative instruments associated with the sale of PCG,
GEO’s former joint venture in the United Kingdom, was reflected in GEO’s Consolidated
Statements of Shareholders’ Equity and Comprehensive Income for 2003.

    With respect to the reclassification of the foreign currency translation loss attributable
to the sale of PCG in July 2003, GEO received a similar comment from the Staff in a letter
dated September 5, 2003 relating to GEO’s Registration Statement on Form S-4 (File No.
333-107709). In addressing this comment, GEO provided the Staff with a response
substantially similar to the language below (Note: the language below has been revised in
certain places to both exclude irrelevant information and include updated information. GEO
can supplementally provide the Staff with an exact copy of the original response upon
request):

GEO inadvertently had not previously recorded its proportionate share of PCG’s
foreign currency translation adjustment in equity. The cumulative foreign currency
translation related